Nos. 01-15-00032-CR & 01-15-00033-CR

IN THE COURT OF APPEALS

FOR THE

FIRST DISTRICT OF TEXAS

HOUSTON, TEXAS

JOE EDDIE ALEJANDRO, Appellant

VS.

THE STATE OF TEXAS, Appellee

APPEAL FROM THE 410th DISTRICT COURT

OF MONTGOMERY COUNTY, TEXAS

THE HONORABLE JUDGE SUZANNE STOVALL S/A, PRESIDING

TRIAL DOCKET NO. 12-05-05610-CR (Count II & III)

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF

TO THE HONORABLE JUSTICES OF THE FIRST COURT OF APPEALS: 

NOW COMES JOE EDDIE ALEJANDRO, Appellant in the above styled and 

numbered cause, and moves this Court to grant an extension of time to file appellant's brief, 

pursuant to Rules 10.5(b) & 38.6 of the Texas Rules of Appellate Procedure, and for good 

cause shows the following:

1. This case is on appeal from the 410th Judicial District Court of Montgomery 

County, Texas.

2. The case below was styled the STATE OF TEXAS vs. JOE EDDIE 

ALEJANDRO, Cause No. 12-05-05610-CR (Count II-III). 

3. On November 6, 2014, Appellant was convicted of Aggravated Sexual Assault 

of a Child (Count II) and Indecency with child, sexual contact (count III). 

ACCEPTED

01-15-00033-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS

4/16/2015 6:05:57 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 4/16/2015 6:05:57 PM CHRISTOPHER A. PRINE Clerk
4. On November 6, 2014, Appellant was sentenced to confinement in the Texas 

Department of Criminal Justice, Institutional Division for 30 years (count II), 10 years 

(count III). 

5. Notice of appeal was timely filed November 10, 2014. 

6. The clerk's record was filed on December 18, 2014; the reporter's record was 

filed on March 16, 2015. 

7. On January 8, 2015, this cause was transferred to the First Court of Appeals 

from the Ninth Court of Appeals.

 8. The appellate brief is presently due on April 16, 2015. 

 9. Appellant requests an extension of time of 60 days from the present date, i.e. 

June 16, 2015. 

10. There have been no previous extensions to file the brief filed in this cause.

 11. Defendant is currently incarcerated.

12. Appellant relies on the following facts as good cause for the requested 

extension:

Due to unforeseen circumstances, counsel has relocated her family and law practice 

from Conroe, Montgomery County, Texas to El Paso, El Paso County, Texas. El Paso is 

almost 800 miles from Conroe. 

Moreover, in the last 30 days, counsel was actively working on another appellate 

brief, STATE OF TEXAS vs. GUADENCIO AGUILAR MEJIA (09-14-00419-CR; 09-14-

00420-CR; 09-14-00421-CR; 09-14-00422-CR), and counsel filed her appellate brief on April 

10, 2015. 
As a result, counsel has not had sufficient time to prepare an adequate Appellant’s 

brief in this case. 

13. This extension is not sought for purpose of delay.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court 

grant this Motion To Extend Time to File Appellant's Brief, and for such other and further 

relief as the Court may deem appropriate.

Respectfully submitted,

/s/ Heather Hall

HEATHER HALL

 State Bar Number: 24026287 

HEATHER HALL & ASSOCIATES 

308 N. Main

Conroe, Texas 77301

conroelaw@gmail.com

936-447-0371

936-647-2592 (Fax) 

Attorney for Joe Eddie Alejandro

CERTIFICATE OF COMPLIANCE

This is to certify that this document complies with requirement of Tex. R. App. P.

Rule 9.4(i)(1),(3). According to the computer program used to prepare the document, this 

document has the following number words: 393 including footnotes. 

/s/ Heather Hall

HEATHER HALL
CERTIFICATE OF SERVICE

This is to certify that on April 16, 2015, a true and correct copy of the above and 

foregoing document was served on the District Attorney's Office, Montgomery County by 

electronic service. 

/s/ Heather Hall

HEATHER HALL