Juan Reyes, Jr. v. State ( 2015 )

ACCEPTED
01-15-00178-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
7/9/2015 3:05:16 PM
CHRISTOPHER PRINE
CLERK
NO. 01-15-00178-CR
FILED IN
1st COURT OF APPEALS
IN THE COURT OF APPEALS FOR HOUSTON, TEXAS
THE FIRST DISTRICT OF TEXAS 7/9/2015 3:05:16 PM
AT HOUSTON CHRISTOPHER A. PRINE
Clerk
JUAN REYES,
Appel/ant,
v.
THE STATE OF TEXAS,
Appel/ee.
Appealed from the 184th District Court
of Harris County, Texas
Trial Court Cause Number 1313736
MOTION FOR EXTENSION OF TIME
TO FILE BRIEF OF APPELLANT
Joseph Salhab
State Bar #17532300
2028 Buffalo Terrace
Houston, Texas 77019
Tel. (713) 528-1005
Fax: (713) 528-2424
josephsalhab@mindspring.com
COUNSEL FOR APPELLANT
JUAN REYES
NO. 01-15-00178-CR
IN THE COURT OF APPEALS FOR
THE FIRST DISTRICT OF TEXAS
AT HOUSTON
JUAN REYES,
Appellant,
v.
THE STATE OF TEXAS,
Appellee.
Appealed from the 184th District Court
of Harris County, Texas
Trial Court Cause Number 1313736
MOTION FOR EXTENSION OF TIME
TO FILE BRIEF OF APPELLANT
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, JUAN REYES, Appellant, by and through his attorney
of record on appeal, Joseph Salhab, files this Motion for Extension of Time
to File Appellant's Brief. In support of said Motion, the Appellant shows the
Court the following:
I.
The Appellant was convicted in the 184th District Court of Harris
County, Texas, on or about February 12, 2015 in Cause Number 1313736,
of Capital Murder and sentenced to life imprisonment without the possibility
of parole. Appellant gave timely notice of appeal.
II.
Appellant's brief was originally due on July 9, 2015. This is
Appellant's first Motion for Extension.
III.
Appellant is requesting the Court grant an extension of forty-five (45)
days for filing the Appellant's Brief until August 23, 2015.
IV.
Appellant's request for an extension of time is based on the fact that
he is engaged in numerous other trial and appellate cases. Significant
cases include:
The State of Texas v. Marquisha A. Williams, in the 248th District
Court of Harris County, Texas. Defendant is charged with
Capital Murder. The case was set for May 26, 2015.
The State of Texas v. Ricky Gaines, in the 184th District Court of
Harris County, Texas. Defendant is charged with Aggravated
Assault. The case is set for July 14, 2015.
The State of Texas v. Byron Chatman, in the 184th District Court,
Harris County, Texas. Defendant is charged with Burglary of a
Habitation. The case is set for July 14, 2015.
The State of Texas v. Ronald Haskell, in the 248 th District Court of
Harris County, Texas. Defendant is charged with Capital
Murder. The case was set April 22, 2015. Change of venue
hearing was set for June 24, 2015.
The State of Texas v. Wilbert Lewis, in the 183rd District Court of
Harris County, Texas. Defendant is charged with Aggravated
Robbery. The case is set for jury trial July 15, 2015.
The State of Texas v. Merrick West, in the 338 th District Court of
Harris County, Texas. Defendant was charged with Aggravated
Robbery. The case is set for July 23,2015.
James Rivera v. The State Of Texas, in the 14th Court of Appeals of
Houston, Texas. Appellant brief was filed May 8, 2015.
Ralph Garcia, Jr. v. The State of Texas, in the 1st Court of Appeals of
Galveston, Texas. Appellant brief was filed June 24, 2015.
Additionally, Appellant's attorney is involved in numerous other trial
and appellate cases, not listed here.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that the
Court grant an extension of forty-five (45) days, until August 23, 2015, to
file Appellant's Brief.
Respectfully submitted,
~c~
JSaitlab -------
State Bar #17532300
2028 Buffalo Terrace
Houston, Texas 77019
Tel. (713) 528-1005
Fax: (713) 528-2424
josephsalhab@mindspring.com
COUNSEL FOR THE APPELLANT
JUAN REYES
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing motion
+-
was delivered to Assistant District Attorney for Har~, Texas, via
notice of electronic filing (NEF), on the day of c= ,2015.
~4~
JOALHAB '-
VERIFICATION
STATE OF TEXAS §
§
COUNTY OF HARRIS §
BEFORE ME, the undersigned authority on this day personally appeared
JOSEPH SALHAB, who being duly sworn has deposed and stated upon
oath:
"My name is JOSEPH SALHAB. I am the Appel/ant's attorney
on appeal in the above-styled and numbered cause. I have
read the above and foregoing Motion to Extend Time to file
Appel/ant's Brief and the facts contained therein are true and
correct."
SUBSCRIBED AND SWORN TO BEFORE ME, the
undersigned authority, on this the 7'fJ. day of -:::Tu-fj , 2015, to
certify which, witness my hand and official seal of office.
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