Ex Parte Jose Eduardo Torres

ACCEPTED
03-14-00169-CR
4205417
THIRD COURT OF APPEALS
AUSTIN, TEXAS
2/19/2015 9:42:33 AM
JEFFREY D. KYLE
CLERK
Nos. 03-14-00169-CR
EX PARTE § IN THE COURT OF APPEALS
FILED IN
3rd COURT OF APPEALS
VS. § THIRD JUDICIALAUSTIN, TEXAS
DISTRICT
2/19/2015 9:42:33 AM
JOSE EDUARDO TORRES § TRAVIS COUNTY, TEXAS
JEFFREY D. KYLE
Clerk
APPELLANT’S EMERGENCY MOTION FOR EXPEDITED CONSIDERATION
From the 207th District Court of Comal County, Texas
Trial Court No. CR2013-127
Hon. Bruce Boyer, Judge Presiding
All briefs in Appellant’s case have been submitted. Appellant’s case was designated as
“Ready to be Set” on October 23, 2014. Thus far, no submission date has been set.
On Thursday February 12, 2015, Appellant’s order of removal was affirmed by the Board
of Immigration Appeals. Appellant is scheduled to be deported from the United States at any
time. Appellant has ninety (90) days to file a Motion to Reopen his immigration case, the
success of which is dependent upon the outcome of this habeas appeal. Appellant’s counsel
respectfully, and humbly, asks this Court to consider expediting consideration of his appeal, with
a resolution on or before Monday May 4, 2015.
Counsel understands the vast number appeals pending before this Court and understands
the Court reaches each case as quickly as it can. It is only due to Appellant’s dire situation that
he makes this extraordinary request. Once Appellant’s time to file a Motion to Reopen is over,
the odds of his ability to return to the United States even if he were to succeed in this habeas
appeal are extremely remote. Counsel makes this request only with the intention of representing
his client zealously and doing all he can to protect his interests.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests that
this Court grant the Appellant’s request.
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 19th day of February, 2015 a copy of the foregoing
“Motion for Extension of Time to File Motion for Rehearing” has been electronically filed with
this Court, and served on the Comal County District Attorney’s Office.
/s/ ROBERT A. JIMENEZ