1 No. 14- 14 -00455- CR

In the

Court of Appeals

For the

Fourteenth District of Texas

At Houston

_________________________________________________________

Trial Court Cause No. 1406639

In the 1 85 th District Court

of Harris County, Texas

_________________________________________________________

GREGORIO MORENO,

Appellant

v.

THE STATE OF TEXAS

, Appellee

___________________________________________________________

MOTION FOR EXTENSION OF TIME TO FILE

___________________________________________________________

VIVIAN R. KING

State Bar No. 00784399

2202 Alabama St.

Houston, Texas 77004

Tel.: (713) 222-2019

eFax: (877) 753-6706

Email: VivianRKing@msn.com

Appointed Attorney for Appellant ACCEPTED

No. 14-14-00455-CR

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

2/3/2015 12:38:07 PM

CHRISTOPHER PRINE

CLERK2

TO THE HONORABLE COURT OF APPEALS:

NOW COMES GREGORIO MORENO , the Appellant herein, and moves

the Court for an extension of time to file Appellant's Brief in this cause, pursuant to

TEX. R. APP. PROC. Rules 10.5 (b)(2) and 38.6(n) , and in support thereof

would show the C ourt as follows:

I.

The Appellant in this cause pled not guilty in the 185 th District Court of

Harris County, Texas in cause number 1406639 plead not guilty and had a jury

trial. The jury found Appellant guilty and sentence was assessed 5 0 years in the

T exas Department of Corrections, Institutional Division on May 23, 2014 . Notice

of Appeal was filed on May 23, 2014.

II.

The Clerk’s record was timely filed

.

The Reporter’s record was timely filed.

III.

Appellant’s attorney is requesting an extension of time to file Appellant’s

Brief to February 09 , 2015.

I V.

Appellant’s attorney is requesting this extension of time to file Appellant’s Brief

for the following two reasons:3

(1) The record contains over 15 volumes and the undersigned attorney is only

60% throu gh the record.

(2) The undersigned attorney has been unable to complete Appellant’s brief due

to moving her office of 22 years and discovering/firing her secretary for

embezzlement of about $30,000.00 (for which the attorney has not had time to file

charges). 2014 was a rough year but if given more time, Appellant’s brief will be

properly completed.

The Appellant in this case was sentenced to 50 years so I pray this

Honorable Court grants this extension so the undersigned appointed attorney can

properly prose cute this case on appeal.

WHEREFORE, PREMISES CONSIDERED, the undersigned counsel, on

behalf of Appellant, respectfully prays that this Honorable Court grant this

extension to February 09, 2015

.

RESPECTFULLY SUBMITTED,

/s/ Vivian R. King

VIVIAN R. KING

Appointed Attorney for Appellant

Texas Bar No. 00784399

2202 Alabama St.

Houston, Texas 77004

(713) 222

- 2019 office

( 877 ) 753

- 6706 e Fax

VivianRKing@ msn.com . Email4 CERTIFICATE OF SERVICE

As Attorney of Record for Appellant, I do hereby c ertify that a true and correct

copy of the above and foregoing document was efiled with the office of the

Honorable Devon Anderson , Harris County Distric t Attorney, via the mandatory

electronic filing system on February 03 , 2015

.

/s/ Vivian R. King

VIVIAN R. KI NG