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 ofsame would show: I. The trial court below is the 338TH District Court ofHarris County, Texas. The trial court case number is 1344348. Appellant was convicted ofcapital murder and sentencedto Life in the Texas Department ofCriminal Justice

- Institutional Division. II. A Motion for New Trial was filed on June 10, 2014. Pro-Se Notice ofAppeal 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 briefis December 31, 2014. IV. One previous Extension ofTime 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--------,



### VI. This request is not made for the purpose ofdelay, but to insure Appellant's right to appellate review in this case. The undersigned maintains an active trial and appellate caseload. During the pendency ofthe 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 grandjury investigations (state and federal) which have been time-consuming and interruptedthe undersigned's schedule for other matters. The undersigned has reviewedthe 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 briefin this matter. WHEREFORE PREMISES CONSIDERED, the undersigned prays that the Court extend the due date ofappellant's briefuntil 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 ISUBSCRIBED AND SWORN TO BEFORE , the undersigned authority on this 31stday ofDecem\mr
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I//)1111\\\\\\ A true ancl correct copy ofAppellant's Motion for Extension ofTime 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