NO. 14-15-00243-CR

IN THE COURT OF APPEALS

FOR THE 

FOURTEENTH SUPREME JUDICIAL DISTRICT OF TEXAS

AT HOUSTON

_______________________________________________________

JOSEPH BARUCH RODRIGUEZ

Appellant

v.

THE STATE OF TEXAS,

Appellee

_______________________________________________________

Appeal from Cause No. 12CR2802

In the 405th District Court of 

Galveston County, Texas

__________________________________

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE 

BRIEF FOR APPELLANT

_________________________________

To the Honorable Justices of the Court of Appeals:

Appellant, JOSEPH BARUCH RODRIGUEZ, by and through his Counsel of 

Record, JARED ROBINSON, files this Unopposed Motion to Extend Time to File Brief

and in support shows this Court the following:

I.

Appellant pled guilty to one count of Possession of a Controlled Substance, in the 

amount of 1 to 4 grams on October 17, 2012. The court assessed punishment at 5 years 

Deferred Adjudication Probation. 

ACCEPTED

14-15-00243-CR

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

8/31/2015 7:36:28 AM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 8/31/2015 7:36:28 AM CHRISTOPHER A. PRINE Clerk
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On September 29th, 2014, the State of Texas filed a Motion to Adjudicate GuiltRevoke Community Supervision. A contested hearing was held on December 18th, 2014, 

and the court found “true” that the defendant had violated conditions 1, 16A, 19, 22, and 

26 of defendant’s probation. On February 13, 2015 the court sentenced appellant to 

confinement in the Texas Department of Criminal Justice for a period of Six (6) years.

II.

Appellant’s brief is due on or before August 30, 2015. Appellant’s counsel 

respectfully requests an extension for at least sixty days to file Appellant’s brief. The 

Assistant District Attorney handling the case, Rebecca Klaren, has indicated the State of 

Texas is unopposed to Appellant’s request for an extension.

Appellant’s counsel needs additional time to complete his brief and additional 

time to review the Reporter’s Record because of conflicts created by work in other cases. 

More specifically, counsel for Appellant has been diligently preparing for multiple trials 

that were scheduled to begin in Galveston County on August 24th and preparing for 

another trial scheduled to begin in Galveston County on September 14th. This is the first 

request for an extension of time filed with this Court. Therefore Counsel requests that 

this Court extend the time to file Appellant’s Brief until at least October 30th, 2015.

Respectfully Submitted,

JONES ROBINSON, LLP.

/s/ Jared S. Robinson /s/

JARED S. ROBINSON

State Bar No.: 24060506

1100 Rosenberg Avenue

Galveston, Texas 77550
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409.765-5705

409.765.7570 Facsimile

ATTORNEY FOR APPELLANT

CERTIFICATE OF SERVICE

I hereby affirm a true and correct copy of the foregoing was delivered via handdelivery and/or electronic delivery to Rebecca Klaren, Assistant Galveston County 

Criminal District Attorney, on the 29th day of August 2015. 

/s/ Jared S. Robinson 

JARED S. ROBINSON

CERTIFICATE OF CONFERENCE

I hereby certify and affirm that I have communicated on the 29th day of August, 

2015 with Rebecca Klaren, Assistant Galveston County Criminal District Attorney, 

regarding Appellant’s request for an extension of time to file his brief and she has 

indicated that the State of Texas is Unopposed to this request.

/s/ Jared S. Robinson

JARED S. ROBINSON
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