Page 1 of 4

COURT OF CRIMINAL APPEALS CASE NO.: __________________________

FOURTH COURT OF APPEALS CASE NUMBER 04 – 14 – 00565 – CR 

TRIAL COURT CASE NUMBER 2009 – CRP – 000403 – D1

RODOLFO MARTINEZ– SALINAS § COURT OF CRIMINAL APPEALS

 § 

v. § 

 § 

THE STATE OF TEXAS § TRAVIS COUNTY, TEXAS

RODOLFO MARTINEZ – SALINAS’ FIRST MOTION FOR EXTENSION 

OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE JUSTICES OF THE COURT OF CRIMINAL APPEALS

201 W 14TH STREET

AUSTIN, TEXAS 78701 – 1445

Richard J. Gonzalez, the undersigned counsel for Appellant Rodolfo 

Martinez – Salinas, has been unable to complete the Petition for Discretionary 

Review on or before the deadline to file it.

The deadline to file the Petition for Discretionary Review was Friday, 

December 4, A.D., 2015.

The length of the extension sought is from Friday, December 4, A.D., 2015, 

to Monday, January 18, A.D., 2016, a total of forty - five (45) days.

The facts relied on to reasonably explain the need for an extension are:

Between November 4, A.D., 2015, and December 18, A.D., 2015, counsel 

for Rodolfo Martinez – Salinas was scheduled for a court appearance in more than 

eighty – five (85) cases in Laredo, Webb County, Texas, and was scheduled for a 

PD-1647-15

COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS

Transmitted 12/18/2015 2:11:25 PM

Accepted 12/19/2015 10:38:29 AM

ABEL ACOSTA

CLERK
Page 2 of 4

jury trial in at least two cases during that period, which jury trials were avoided 

because the defendant in each case eventually entered a plea of guilty.

Counsel for Rodolfo Martinez – Salinas was engaged in a jury trial in the 

case styled, “The State of Texas v. Juan Carlos Palomares,” Trial Court Cause 

Number: 2015CRS000530 D4, Court of Appeals Number 04 – 15 – 00755 – CR, 

which jury trial ended on October 28, A.D., 2015, and counsel filed the Notice of 

Appeal, and Designation of Clerk’s and Reporter’s Records on Appeal on 

November 30, A.D., 2015.

Counsel for Rodolfo Martinez – Salinas is scheduled for a jury trial in Cause 

Number 2015CRP000624 D4, styled “The State of Texas v. Jessica Lee Carreon,” 

on Monday, January 11, A.D., 2015.

There have been no previous extensions granted regarding the Petition for

Discretionary Review.

The Court of Appeals is the Fourth (4th) Court of Appeals in San Antonio, 

Bexar County, Texas.

The date of the Court of Appeals’ judgment is Wednesday, November 4, 

A.D., 2015.

The case number and style of the case in the Court of Appeals are: 

Case Number: 04 – 14 – 00565 – CR.

Style: Rodolfo Martinez – Salinas v. The State of Texas.
Page 3 of 4

There were no motions for rehearing or en banc reconsideration filed in the 

Fourth Court of Appeals.

Wherefore, premises considered, counsel for Rodolfo Martinez – Salinas 

respectfully requests an extension of time to file the Petition for Discretionary 

Review from Friday, December 4, A.D., 2015 to Monday, January 18, A.D., 2016.

Respectfully submitted,

___________________________________________________

RICHARD J. GONZALEZ

ATTORNEY AT LAW

TEXAS BAR NUMBER 08131600

910 LOGAN AVENUE

LAREDO TX 78040 – 6202

CELL: (956) 401 – 6011

VOICE MAIL: (956) 307 – 9910

EMAIL: RICHARD0477@SBCGLOBAL.NET

CERTIFICATE OF SERVICE

I, Richard J. Gonzalez, counsel for Rodolfo Martinez – Salinas, do hereby 

certify, under oath, that I emailed a true and correct copy of the above and 

foregoing “Rodolfo Martinez – Salinas First Motion for Extension of Time to File 

The Petition for Discretionary Review” to David Reuthinger, Jr., Assistant District 

Attorney, 49th Judicial District of Texas, 1110 Victoria Street Suite 401, PO Box 

1343, Laredo, Webb County, Texas, 78042 – 1343, (956) 523 – 4900, at 

dreuthinger@webbcountytx.gov, on Friday, December 18, A.D., 2015.
Page 4 of 4

___________________________________________________

RICHARD J. GONZALEZ

COUNSEL FOR RODOLFO MARTINEZ – SALINAS