THE STATE OF TEXAS 

IN THE COURT OF APPEALS 

FOURTH SUPREME JUDICIAL DISTRICT 

SAN ANTONIO, TEXAS 

MOTION FOR EXTENSION OF TIME TO FILE BRIEF 

TO THE HONORABLE JUDGE OF SAID COURT 

COMES NOW the Appellant JONATHAN JOSE GUILLEN, by and through his 

undersigned attorney, and respectfully requests that this Honorable Court allow him an extension of time for a period of thirty (30) days in which to file the Appellant's brief. 

The Appellant makes this request under 38.6(d) of the Texas Rules of Appellate Procedure, and shows the following in support of said motion:

I 

The c1erk’s record in this cause was electronically filed on November 25, 2014. 

The Court Reporter’s record was electronically filed on April 28, 2015. Appe1lant’s brief is due no later than July 16, 2015. This is Appellant’s third motion for extension of time.
nine (99) years at TDCJ on October 14, 2014. Counsel was informed the brief was due on May 28, 2015. The record contains fourteen (14) volumes of testimony and legal 

documents. 

III 

This is the third extension requested by the Appellant. The request for more time 

is being made not for the purposes of delay but rather so that justice may be done. 

IV 

Since the brief was due, counsel has completed thirty-seven pages of the Statement 

of Facts and made notes of sixteen potential points of error, which still need to be 

researched, and either included or excluded. Since the entry of the last Court's order granting an extension, counsel has worked overtime and on weekends to focus on the 

completion of the brief, but also to effectively represent all other clients, in State and Federal courts, in and out of jails, inside and outside of Bexar County Courts, as well as 

assisting a colleague, who recently underwent a very serious surgery, with his cases. The 

undersigned also has to return phone calls and make time for other cases and court 

appearances. The undersigned is asking for a thirty (30) day extension but believes that 

the brief will be completed before then. This particular case is fact-intensive with many exhibits, pictures, as well as long videos and telephone calls. 

WHEREFORE, PREMISES CONSIDERED, the Appellant respectfully requests
CAMPION & CAMPION fl//2 ’ALEX J. 2?/PIA1iF% State Bar 0. 1772 5 222 E. Main Plaza San Antonio, Texas 78205 Telephone No. 210/227-5161 Telecopier N0. 210/229-1243 alex'ossc ahoo.com cind cam ionlawfirmcom
Extension of Time To File Brief has on this 16th day of July, 2015, been delivered to the 

Bexar County District Atton1ey's Office, San Antonio, Texas.

4 

KLEX J. /§i4ARFF/ fl
SCHARFF and after being duly sworn did depose and state: 

"My name is ALEX J. SCHARFF. I am familiar with the foregoing Motion For 

Extension Of Time To File Brief. I have read the foregoing document to which this 

affidavit is attached and believe the allegations contained therein are true and correct." 

WITNESS my signature this if; day of July, 20 1 

/ ( SUBSCRIBED AND SWORN to before me on this [I day ofJuly, 2015. 

7 . 

RRVMAN C/L/)/Z"d44 /7 U/44/{4’hLA.-vv “Nov ME Notary Publicfin and for ” My commission Expires Femuarv14.2015 the State of Texas My commission expires: J — /4 » / 3
Appellant. 

,4(LEX’J. RFF / 5/