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 405 th 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 Counse l of

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

and in support show s this Court the following:

I.

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

amount of 1 to 4 grams on Octo ber 17, 2012 . T he 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

CLERK2 On September 29 th , 2014, the State of Texas filed a M otion to Adjudicate Guilt

Revoke Community Supervision. A contested hearing was held on December 18 th , 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 c ourt 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 additio nal

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

More specifically, counsel for Appellant has bee n diligently preparing for multiple trial s

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

another trial scheduled to begin in Galveston County on September 14th

. Th is 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 le ast October 30th, 2015

.

Respectfully Submitted,

J ONES R OBINSON

, LLP.

/s/ Jared S. Robinson /s/

JARED S. ROBINSON

State Bar No.: 24060506

1100 Rosenberg Avenue

Galveston, Texas 775503 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 hand

delivery and/or electronic delivery to Rebecca Klaren

, Assistant Galveston County

Criminal District A ttorney, on the 29 th d ay of August 2015

.

/s/ Jared S. Robinson

JARED S. ROBINSON

CERTIFICATE OF CONFERENCE

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

2015 with Rebecca Klaren, Assistant Galveston Co unty 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. ROBINSON4