IN THE COURT OF APPEALS FOUR TH COURT OF APPEALS DISTRICT OF TEXAS
AARON GERARD RODRIGUEZ
VS. N O. 04 -15- 00 401- CR
STATE OF TEXAS

S ECOND M OTION TO EXTEND TIME TO FILE BRIEF
TO THE HONORABLE COURT OF APPEALS: COMES NOW the Appellan t, Aaron Gerard Rodriguez , and respectfully moves the Court to extend the time for filing the Brief f or Appellant fo r 30 days , until December 12, 2015 , and in support of said
motion would show the Court as follows:
I. This is an appeal from a judgment adj udicating guilt, revoking community supervision, and assessing a 20

- year sentence . Appellant was sentenced in Cause No

. 2011 -CR- 6071 , styled State of Texas v. Aaron Gerard Rodriguez , on June 2 , 2015 , in the 144 th District Court of Bexar County, Texas, Hon. Lorina Rummel presiding. ACCEPTED 04-15-00401-CR FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 11/12/2015 9:31:43 AM KEITH HOTTLE CLERKII.
No m otion for new trial was filed

. Appellant’s notice of appeal was timely filed on J une 22 , 201 5

. III
The clerk’s record of the trial was filed electronically with the Court of Appeals on Ju ly 2 0, 2015

. The reporter’s rec ord ( 2 volume s by Kay Gittinger ) w as filed electronically on September 10 , 2015

. A p pellant’s brief is due on No v ember 12, 2015. This motion is timely, pursuant to Rule 38.6(d), T.R.A.P. One prior reques t for an extension to file Appellant’s brief ha s be en filed and granted.

. IV.
A ppellant requests a 30

- day extension to file his brief, until December
12 , 2015

. During the previous month, counsel has e

- filed his briefs in the following case: (1) No. 04

- 1 5

- 00 3 82

- CR, Richard Salas v . State of Texas , f

iled O ctober 21 , 2015 , and (2) No. 0 4

- 15

- 002 89

- CR, Rodney Joe Garrett v. State of Texas , filed on November 9 , 2015

. Counsel is presently working on
his brief in No s . 04

- 1 5

- 00 420

- C R & 04

- 14

- 00421

- CR , Jo s e Luis Garza

Ramirez v. State of Texas. During the previous month, counsel has also filed
his response to order proposing to dismiss appeal in No. 04

- 15

- 00 5 92

- CR,
David Devan Trevino v. State o f Texas , filed November 2 , 2015.V. Extenuating Circumstances. The undersigned attorney has been the sole appellate att orney in the Bexar County Public Defender’s Office since September 24, 2015, when the employment of other appellate counsel in this office ended and he assumed representation in all but two of the other attorney’s cases. This effectively more than doubled the undersigned counsel’s caseload, a situation which will continue until a replacement counsel his hired. The last two briefs which the undersigned counsel filed were from the other attorney’s caseload, and the Rodney Joe Garrett reporter’s record consis ts of 12 volumes, necessitation a lengthy preparation
time. WHEREFORE, the Appellant requests this Court to extend the time for filing the brief for Appellant until December 12 , 2015

. Respectfully submitted , /s/ Michael D. Robbins M ICHAEL D. ROBBINS Assistant Public Defender Paul Elizondo Tower 101 W. Nueva St., Suite 3 7 0 San Antonio, Texas 7820 5 (210) 335

- 0701 FAX (210) 335

- 0707 mrobbins@bexar.org Bar No. 16984600 ATTORNEY FOR APPELLANTCERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing first motion to extend time to file brief has been emailed to the Bexar County District Attorney’s Of fice, Appellate Division , Paul Elizondo Tower, 101 W. Nueva St., Suite 7 1 0 , San Antonio, Texas 78205; on November 12 , 2015.
/s/ Michael D. Robbins MICHAEL D. ROBBINS A ssistant Public Def ender