p a n t'• IN THE COURT OF CRIMINAL APPEALS 

## 2015JUN25 PM 

## 5?!' AND 384th JUDICIAL DISTRICT COURT

CAUSE NO. 20020D03178-168-2 No. WR-67,418-02 In the 384th District Court (transferred from the 168th District Court) El Paso County, Texas The Honorable Patrick Garcia, Judge Presiding WR-67,418-02 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 6/25/2015 4:48:11 PM H0R!lActefJteW6^i(2015 1:09:00PM DISTRICT ClJiHK ABELACOSTA CLERK
t.l. S'AwU L,UUr;l !.
nx IHltVED 

### EX P^RTE MICHAEL JACQUES, Applicant COURTOFCRIMINALAPPEALS 6/26/2015 ABElAedSTA, CLERK

JOINT MOTION FOR EXTENSION COME NOW the Applicant, Michael Jacques, by and through his counsel, the El Paso County Public Defender's Office, and State of Texas, by and through her counsel, the Honorable Lily Stroud, and HEREBY jointly move the Court of Criminal Appeals grant the habeas court and counsel an extension from the current timeline of 

### Wednesday, July 29, 2015, to Friday, the 30th of October, 2015. In support of the joint motion, the parties show: 1) The evidentiary hearing on the instant Application was held 

### on June 16th and 23rd in the 384th District Court, with two different court reporters.

Joint Motion for Extension 

# ELECTRONIC RECORD

### 2) The transcripts for the hearing have been requested and are 

### necessary for the parties and the 384th District Court to utilize in the preparation. of the parties' findings of fact 

### and conclusions of law, and for the 384th District Court's review thereof and ultimate entry of its findings of fact and conclusions of law for submission to the Court. 

### 3) It is believed that the preparation of such transcripts, and 

### the parties' and the 384th District Court's findings of fact and conclusions of law will require additional time beyond 

### the present deadline, and that due to the Court's vacation schedule, that a continuance must be requested at this time to ensure that the court reporters, the parties, and the 

### 384th District Court can complete the remaining matters



## • needed to comply with this Court's Order entered April 1st of this year. 

### 4) Attached hereto is the affidavit of Lisa De Mello, the court 

### reporter for the all day hearing held June 16, 2015, representing that she needs 60 days from today's date to 

### complete the transcript for that portion of the hearing. 5) This is the first request for a continuance to extend the 

### time to finish the matters remaining after the 384th District Court's evidentiary writ hearing. This Court previously 

## granted an extension of 60 days for the 384th District Court Joint Motion for Extensionto resolve earlier fact issue regarding the compliance of the 

### Applicant's memorandum with Rule 73.1(d) of the Texas Rules of Appellate Procedure. 

### 6) The parties are jointly seeking this extension not .for purposes of delay but to see that justice is done. WHEREFORE, the parties respectfully request the Court grant this Joint Motion and extend the time for the parties and the 

### Court to complete all matters pertaining to Application by Friday, October 30, 2015, and for any other relief deemed proper.

EL PASO COUNTY PUBLIC DEFENDER Attorneys for the Defendant
By: ERIC WILLARD Deputy Public Defender State Bar No. 00795745 500 E. San Antonio, Ste. 501 El Paso, Texas 79901 915)546-8185/FAX (915)546-8186

JAIME ESPARZA DISTRICT ATTORNEY 34th JUDICIAL DISTRICT

LILY STROUD ASST. DISTRICT ATTORNEY DISTRICT ATTORNEY'S OFFICE 201 EL PASO COUNTY COURTHOUSE 500 E. SAN ANTONIO EL PASO, TEXAS 7 9901 (915) 546-2059/FAX (915) 533-5520 SBN 24 046929 Joint Motion for ExtensionCERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing was hand-delivered to the Honorable Patrick Garcia, 384th District Court Judge at the 384th District Court, to the 

### District Attorney's Office for the 34tl1 Judicial District, and the El Paso County Public Defender's Office, all at 500 E. San Antonio, El Paso, Texas 79901, and to the Applicant, Michael 

### Jacques, at the El Paso County Detention Facility<£-Cell 320, 801 

## Overland, El Paso, Texas 79901, on this the c^^day of June, 2015.

Joint Motion for Extension

### Ex parte: MichaelAngelaJacques :,, ,R |f,. , TTQRHc ., CauseNumber20020D03J78-384-02' 'jaIHEE.ESPARZA 2015 JUN25 ?H I-.5I CourtReporter's AffidavitofForExtension ofTimeTo File Record on Appeal June 25, 2015 I, LisaMarie De Meilo, CSR, Official. CourtReporterin and for the Council ofJudges Administration of ElPasoCounty, Texasreceived noticeofAppeal intheabove-referenced cause. 1am requestingan Extension ofTimeto file Reporter's Record . 1willbeabletofilethis Record within 60days. IfI. am able tocomplete andfiletheReporter'sRecordsoonerthanthis date, Iwill, ofcourse, do soat the earliestopportunity.



### eOUHtYOfltPASO 

## }
TOBEFOREME 

# SSSB5SSESS5 ^-yncn NOTARYPUBLIC 

### /$/ LisaMarieDeMe-IJo
.-yrf^i Lisa Marie De Meilo, CSR CSR#3313 Expiration: 12/31/15 Council ofJudges Administration 500 East San Antonio, Room 101 '£! Paso, Texas 79901. (915) 546-2000, ext. 4352 (915)546-2019 (fax) ldemello@ejxounty.eom