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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 185th 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

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 2/3/2015 12:38:07 PM CHRISTOPHER A. PRINE Clerk
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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 Court as follows:

I.

The Appellant in this cause pled not guilty in the 185th 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 50 years in the 

Texas 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.

IV.

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

for the following two reasons: 
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(1) The record contains over 15 volumes and the undersigned attorney is only 

60% through 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 prosecute 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. Email
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CERTIFICATE OF SERVICE

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

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

Honorable Devon Anderson, Harris County District Attorney, via the mandatory 

electronic filing system on February 03, 2015.

 /s/ Vivian R. King

VIVIAN R. KING