1

No. 04-15-00164-CR

IN THE 

FOURTH COURT OF APPEALS

OF TEXAS

AT SAN ANTONIO, TEXAS

LEANDRE V. HILL APPELLANT

V.

THE STATE OF TEXAS APPELLEE 

FIRST MOTION TO EXTEND TIME 

TO FILE APPELLANT’S BRIEF

TO THE HONORABLE JUSTICES OF THE FOURTH COURT OF 

APPEALS OF TEXAS:

COMES NOW, LEANDRE V. HILL, the appellant in the above styled and 

numbered cause, pursuant to Texas Rules of Appellate Procedure 10.5(b) and 

38.6(d), through the undersigned counsel, files this motion to extend time to file the 

appellant’s brief. In support of this motion the appellant respectfully shows the 

following:

I. Deadline for filing the appellant’s brief: 

The current deadline for filing the appellant’s brief is July 23, 2015. 

TEX.R.APP.P. 4.1(a) and 38.6(a)(2). 

ACCEPTED

04-15-00164-CR

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

7/22/2015 1:00:17 PM

KEITH HOTTLE

CLERK

 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 7/22/2015 1:00:17 PM KEITH E. HOTTLE Clerk
2

II. Length of the extension sought:

Counsel for appellant seeks a thirty (30) day extension to file the appellant’s 

brief, until August 21, 2015. See TEX. R. APP. P. 4.1(a). 

III. Facts relied on to reasonably explain request for extension:

Counsel for appellant seeks this extension of time to file the appellant’s brief 

for the following reasons:

A. The undersigned has recently filed briefs in the following cases:

1. Brandon Master v. The State of Texas, No. 04-15-00100-CR (Appellant’s 

brief filed on June 24, 2015);

2. Brandon Master v. The State of Texas, No. 04-15-00101-CR (Appellant’s 

brief filed on June 24, 2015);

3. Gilbert M. Zepeda v. The State of Texas, No. 04-14-00775-CR 

(Appellant’s brief filed on July 2, 2015)

4. Ramon Davidson v. The State of Texas, No. 04-15-00209-CR (Appellant’s 

brief filed on July 9, 2015).

B. The undersigned has upcoming deadlines in the following cases:

1. Sabrina Nicole Angel v. The State of Texas, No. 04-15-00235-CR 

(Appellant’s brief due to be filed on July 31, 2015);

2. Sabrina Nicole Angel v. The State of Texas, No. 04-15-00236-CR 
3

(Appellant’s brief due to be filed on July 31, 2015);

3. LeAndre V. Hill v. The State of Texas, No. 04-15-00164-CR (Appellant’s 

brief due to be filed on July 23, 2015);

4. Arturo Rosales v. The State of Texas, No. 04-15-00225-CR (Appellant’s 

brief due to be filed on August 12, 2015);

5. Arturo Rosales v. The State of Texas, No. 04-15-00226-CR (Appellant’s 

brief due to be filed on August 12, 2015);

6. Arturo Rosales v. The State of Texas, No. 04-15-00227-CR (Appellant’s 

brief due to be filed on August 12, 2015);

7. LeAndre V. Hill v. The State of Texas, No. 13-15-00152-CR (Appellant’s 

brief due to be filed on August 19, 2015).

C. The undersigned will take vacation leave on July 23, 2015 and July 24, 2015.

D. July 3, 2015 was a county holiday.

IV. Number of previous extensions requested:

This is the first extension of time requested in this case.

V. Not for delay:

This extension of time is not sought for the purpose of delaying the resolution 

of this appeal. He does not believe the additional time requested will prejudice or 

inconvenience the State.
4

VI. Appellant’s status:

The Appellant is presently in the custody of the TDCJ-Institutional Division 

serving a 6-year sentence under cause number 2012CR9686. That sentence is being 

served concurrently with the sentence imposed in this case.

PRAYER

THEREFORE, counsel for the appellant prays that this Court issue an order 

granting the extension of time of thirty (30) days to file the appellant’s brief in the 

above case, and grant all such relief as is fair and just.

 Respectfully submitted, 

RICHARD B. DULANY, JR.

Texas Bar No. 06196400

Assistant Public Defender

Bexar County Public Defender’s Office

101 W. Nueva St., Suite 370

San Antonio, Texas 78205

(210) 335-0701

(210) 335-0707 fax

Richard.Dulany@bexar.org

/s/ Richard B. Dulany, Jr.

___________________________________

RICHARD B. DULANY, JR.

ATTORNEY FOR APPELLANT
5

CERTIFICATE OF SERVICE AND COMPLIANCE

The undersigned does hereby certify that a copy of the above motion was 

delivered by electronic service to the Appellate Section of the State’s Attorney: 

Nicholas A. LaHood, Criminal District Attorney, Bexar County District Attorney’s 

Office, Appellate Section, 101 W. Nueva St., Suite 710, San Antonio, Texas 78205, 

on July 22, 2015. The word count is 679.

/s/ Richard B. Dulany, Jr.

___________________________________

RICHARD B. DULANY, JR.