Sergio Delgado Dominguez v. State ( 2015 )

ACCEPTED
03-14-00086-CR
4461115
THIRD COURT OF APPEALS
AUSTIN, TEXAS
3/11/2015 3:14:49 PM
JEFFREY D. KYLE
CLERK
CAUSE NO. 03-14-00086-CR
FILED IN
3rd COURT OF APPEALS
EX PARTE: § AUSTIN,COURT
IN THE APPEALS TEXAS
3/11/2015 3:14:49 PM
§
JEFFREY D. KYLE
SERGIO DELGADO DOMINGUEZ § THIRD DISTRICT OF ClerkTEXAS
APPLICANT §
APPLICANTS’ MOTION TO EXTEND TIME TO FILE BRIEF
NOW COMES, Petitioner, SERGIO DELGADO DOMINGUEZ, through
his attorney of record, JUAN R. GONZALEZ, respectfully requests this Honorable
Court to extend the time to file Petitioner’s Brief in Support of the Notice of Appeal,
Appellant’s Brief. Petitioner requests the extension in the interest of justice and
not for delay.
1. Petitioner is the person named as the defendant in the above-entitled action,
2. Petitioner’s attorney was present in two Master Calendar Hearings and one
Bond Hearing in Immigration Court in San Antonio, Texas on March 9, 2015.
3. Petitioner’s attorney is transiting into a new office location, and due to
unforeseen circumstances has been unable to connect to the internet access.
For the reasons stated above, Petitioner requests this Honorable Court to
extend the time to file Petitioner’s brief an additional thirty (30) days to April 9,
2015.
Dated: March 10, 2015.
Respectfully Submitted,
___/S/Juan R. Gonzalez_____
Juan R. Gonzalez
Juan R. Gonzalez, PLLC
8023 Vantage Drive, Suite 400
San Antonio, Texas 78230
O: (210) 591-8878
F: (210) 579-1011
jrgonzalez@jrgonzalezlawfirm
.com
CERTIFICATE OF SERVICE
I, JUAN R. GONZALEZ, hereby certify that a true and correct copy of Motion to
Extend Time to File Brief has been forwarded by facsimile on this, the 11 day of
March, 2015 to:
Georgette Hogarth
Assistant District Attorney
State Bar No. 24007129
P.O. Box 1748
Austin, Texas 78767
(512) 854-9400
Fax No. 854-4206
___/S/Juan R. Gonzalez_____
JUAN R. GONZALEZ