Francisco Javier Gonzalez v. State

ACCEPTED
04-14-00709-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
3/11/2015 8:10:00 PM
KEITH HOTTLE
CLERK
Nos. 04-14-00709-CR
STATE OF TEXAS § IN THE COURT OF APPEALS
FILED IN
4th COURT OF APPEALS
VS. § SAN ANTONIO,
FOURTH JUDICIAL TEXAS
DISTRICT
3/11/2015 8:10:00 PM
FRANCISCO JAVIER GONZALEZ § BEXAR COUNTY,
KEITHTEXAS
E. HOTTLE
Clerk
MOTION FOR EXTENSION OF TIME
TO FILE OPENING BRIEF
From the 399th District Court of Bexar County, Texas
Trial Court No. 2011-CR-9697
Hon. Ray J. Olivarri, Judge Presiding
In accordance with Tex. R. App. P. 10.5(b), the undersigned submits the following:
Appellant’s brief is due to be filed on Monday, the 16th of March, 2015. The undersigned
requests additional time to prepare and file Appellant’s opening brief. Counsel is still waiting
on the trial court to submit written findings of fact and conclusions of law. Counsel was
informed last week that these findings are being prepared and should be completed soon.
Findings of fact and conclusions of law would assist all parties in this appeal and Counsel would
request additional time to allow the trial court to enter its findings. Counsel has already been
working on Appellant’s brief to insure that it is prepared as expeditiously as possible. Counsel
requests an extension of twenty-one (21) days, to and including Monday, April 6, 2015. This is
Appellant’s second request for an extension.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests that this
Court grant the requested extension.
Respectfully submitted,
Robert A. Jimenez
De Mott, McChesney, Curtright & Armendariz, LLC.
800 Dolorosa Street, Suite 100
San Antonio, Texas 78207
210/354-1844
210/212-2116 - fax
By: /s/ Robert A. Jimenez
SBN: 24059125
CERTIFICATE OF SERVICE
I hereby certify that on this the 11th day of March, 2015 a copy of the foregoing “Motion
for Extension of Time to File Appellant’s Opening Brief” has been electronically filed with this
Court, and will be served to the Bexar County District Attorney’s Office on March 12, 2015.
/s/ ROBERT A. JIMENEZ