ACCEPTED 04-14-00372-CR FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 1/22/2015 5:26:35 PM KEITH HOTTLE CLERK NO. 04-14-00372-CR and 04-14-00370-CR ANDRES RAMON JUAREZ § IN THE FOURTH DISTRICT FILED IN 4th COURT OF APPEALS § SAN ANTONIO, TEXAS § 1/22/2015 5:26:35 PM VS. § COURT OF APPEALS KEITH E. HOTTLE § Clerk § STATE OF TEXAS § SAN ANTONIO, TEXAS

MOTION FOR EXTENSION OF TIME TO FILE STATE’S BRIEF TO THE HONORABLE JUDGES OF THE FOURT COURT OF APPEALS: NOW COMES Nicholas “Nico” LaHood, Criminal District Attorney of Bexar County and Counsel for the State of Texas, and files this Motion asking that the Court extend the time for filing the State’s brief.

Appellant pled no contest to two aggravated robbery indictments on February10, 2014. On April 28, 2014, after hearing evidence from both sides, the trial court sentenced appellant to 45 years in the Texas Department of Criminal Justice. Appellant filed a notice of appeal on May 14, 2014. The reporter’s record was filed on June 3, 2014. Appellant’s original appointed counsel filed an Ander’s brief on November 10, 2014, noting there was no meritorious issues to present to the court. The appellant filed a pro se Motion for a Constitutional Review of Appellate Motion to Withdraw as Counsel in Appellant’s Appeal. The State’s brief was due January 17, 2015. This is the State’s first motion for extension and the State requests a 30 day extension to February 16, 2015.

The appellant’s motion makes allegations without support or benefit of the record, and the State needs more time to respond appropriately.

2) Counsel has been working on the following appeal: a. In re J.B., 04-14-0079-CV b. Paulino Flores v. State, 04-14-00315-CR 3) Counsel recently filed the following briefs in the First Court of Appeals: a. Roland Alvarado v. State, 01-14-00547-CR 4) Counsel recently filed the following briefs in the Fourth Court of Appeals: a. Filiberto Sierra v. State, 04-14-00279-CR a. In re K.B.F. and Z.A.R., 04-14-004392-CV b. Frances Rosalez Ford v. State, 04-14-00025-CR c. Mark Anthony Garcia v. State, 04-13-00818-CR d. Arthur Thomas v. State, 04-14-00025-CR e. In re C.H.R., a juvenile, 04-14-00336-CV f. State v. Robert Romo, 04-14-00197-CR Therefore, counsel respectfully asks the Court to grant this extension time to file the State’s brief in this case.

WHEREFORE, PREMISES CONSIDERED, Counsel for the State prays that the Court grant an extension of time to February 16, 2015 for filing the State’s brief.

Respectfully submitted, Nicholas “Nico” LaHood Criminal District Attorney Bexar County, Texas /s/ Lauren A. Scott _____________________ Lauren A. Scott

_/s/ Lauren A. Scott