No. 01-14- 00 544- CR

JOSE VELEZ § IN THE FIRST COURT

Appellant §

v. § OF APPEALS

THE STATE OF TEXAS §

Appellee § SAN ANTONIO , TEXAS

MOTION FOR EXTENSION OF TIME TO FILE STATE’S BRIEF

TO THE HONORABLE JUDGES OF THE COURT OF APPEALS:

NOW COMES Susan D. Reed, Criminal District Attorney of Bexar

County and Counsel for the State of Texas, and files this motion asking that the

Court extend the time for f iling the State’s brief in the following cause.

A.

1. This case is on appeal from the 187 th Judicial District Court, Bexar

County, Texas.

2. The style and number of the case in the trial court is Th e State of Texas v.

Jose Velez

, Cause number 2013CR0307C.

3. Appellant was convicted o f the offense of Murder.

4. Punishment was assessed at 45 years.

5. The present deadline for filing the State’s brief is December 31 st , 2014.

6. The State seeks an extension of time for 30 days to January 30th, 2015. ACCEPTED 01-14-00544-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 12/31/2014 11:12:02 AM CHRISTOPHER PRINE

CLERK7. This is the State’s first extension of time to file the State’s brief.

B.

This extension is not sought for the purpose of delaying this appeal,

but for the following reasons:

1. Counsel for the State has recently completed the State’s briefs in the

following causes:

a

. In the Interest of T.D., et. al , Children, Cause No. 04

- 13

- 00562

- CV

b

. Christopher Lamar v. The State of Texas , Cause Nos. 04

- 13

- 00326

- CR & No. 04

- 13

- 00327

- CR

c

. In the Matter of H.T.S. , Cause No. 04

- 11

- 00847

- CV

d. In the Interest of K.M.L.H., a Child , Cause No. 04

- 13

- 00779

- CV

e

. In the matte r of A.K.A. , Cause No. 04

- 13

- 00666

- CV

f. Shameon Eshae Henry v. The State of Texas , Cause No. 04

- 13

- 00730

- CR

g. Aaron Alvarez v. The State of Texas , Cause No. 04

- 13

- 00703

- CR

h. The State of Texas v. Aaron Murray , Cause No. 04

- 14

- 00328

- CR

i. In the Interest of A.M.M. & M.B.L.,Children, Cause No. 04

- 14

- 00248

- CV

j. In the Interest of J.F. , Cause No. 04

- 14

- 00316

h. Charles Warren v. The State of Texas , Cause No. 04

- 14

- 00069

- CR

i. Ex Parte Kenneth Vela , Cause No. WR

- 37,070

- 02

j. In the Interest of J. J

. C., A.C., Je.J.C. , Cause No. 04

- 14

- 00 577k. Darrick Davon Oliver v The State of Texas , Cause No. 04

- 14

- 00261

- CR

l. Philip Garay v. The State of Texas , Cause No. 04

- 14

- 00252

- CR

2

. Counsel is presently working on the State’s brief in the following cause s :

a. Jesus Padilla v. The State of Texas , Cause No. 0 4

- 14

- 00 095

- CR

3

. The State needs additional time to conduct the necessary research and

r eview t he entire re cord to ad equately respond to appellant’s co ntentions.C.

WHEREFORE PREMISES CONSIDERED

, Counsel for the State

prays that the Court grant this extension of time to January 30 th , 201 5 , for filing the

State’s brief.

Respectfully submitted, Susan D. Read Criminal District Attorney Bexar County, Texas

/s/ Mary Beth Welsh

_ Mary Beth Welsh Assistant Criminal District Attorney Bexar County, Texas Paul Elizondo Tower 101 W. Nueva, Suite 370 San Antonio, Texas 78205 (210)335

- 2782 S tate Bar No. 00785215 mwelsh@bexar.org (On Appeal) Attorney for the StateC ERTIFICATE OF SERVICE

I, MARY BETH WELSH, Assistant Criminal District Attorney,

Bexar County, Texas, hereby certify that a true copy of the above and foregoing

Motion for Extension of Time to File State’ s Brief was mailed to C. Wayne Huff

,
Attorney for Appellant, P.O. Box 2334, Boerne , Texas 78 006

.

/s/ Mary Beth W

elsh

_ Mary Beth Welsh