Case No: 01-14-00593-CR 

TONY ESCOBAR § 

§ 

§ 

§ 

§ 

IN THE COURT OF APPEALS 

vs. FIRST DISTRICT 

STATE OF TEXAS HOUSTON, TEXAS 

APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE BRIEF 

TO THE HONORABLE COURT OF APPEALS: 

COMES NOW, Appellant, by and through the undersigned attorney, and moves this 

Court to enter an Order extending the time in which to file appellant's brief in the 

above-referenced cause and in support of same would show: 

I. 

The trial court below is the 338TH District Court of Harris County, Texas. The trial 

court case number is 1344348. Appellant was convicted of capital murder and sentenced to 

Life in the Texas Department of Criminal Justice - Institutional Division. 

II. 

A Motion for New Trial was filed on June 10, 2014. Pro-Se Notice of Appeal was 

filed on July 3, 2014. The Trial Court's Certification regarding the Defendant's Right of 

Appeal was signed on July 7, 2014. 

III. 

The current deadline for filing Appellant's brief is December 31, 2014. 

IV. 

One previous Extension of Time has been requested by the undersigned. 

v. 

The undersigned is requesting an extension until February 2 , 2015. 

ACCEPTED

01-14-00593-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS

12/31/2014 11:10:04 AM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 12/31/2014 11:10:04 AM CHRISTOPHER A. PRINE Clerk
, 

VI. 

This request is not made for the purpose of delay, but to insure Appellant's right to 

appellate review in this case. The undersigned maintains an active trial and appellate 

caseload. During the pendency of the first extension request, the undersigned has been 

simultaneously researching and preparing additional appellate matters in this Court 

[Diamond 14-14-00244-CR] & [Nunn 14-14-00704-CR]. The undersigned also has other 

matters pending before this Court and the First Court of Appeals. The undersigned 

continues to investigate and prepare other trial court level cases, including capital murder 

cases in Galveston County and Harris County. The undersigned is currently involved in 

several grand jury investigations (state and federal) which have been time-consuming and 

interrupted the undersigned's schedule for other matters. The undersigned has reviewed the 

trial court transcript and clerk's record in this matter (including conferencing with the 

official court reporter concerning her notes relating to the transcript) and will need 

additional time to identify the points of error to be raised, conduct legal research and 

prepare the appellate brief in this matter. 

WHEREFORE PREMISES CONSIDERED, the undersigned prays that the Court 

extend the due date of appellant's brief until February 2, 2015. 

R~ 

Wayne T. Hill - SBOT: 09656300 

4615 Southwest Freeway, Suite 600 

Houston, Texas 77027 

Tel: (713) 623-8312 

Fax: (713) 626-0182 

wthlaw@aol.com 

Attorney for Tony Escobar 

i 

I 
SUBSCRIBED AND SWORN TO BEFORE , the undersigned authority on this 

31 stday ofDecem\mr .. 2014 . • ,,\\\1 ,,,,,,,, ,, .. p...HUR 11 

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y Public in and for the State of Texas 

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A true ancl correct copy of Appellant's Motion for Extension of Time to File Brief 

will be delivered to: The Harris County District Attorney's Office - Appellate Division, 

1201 Franklin, 6th Floor, Houston, Texas 77002. ~ 

Wayne T. Hill