Cause No. 428298 %M S&/\`_' mirimiiypli<iuii STATE OfTEXAS, § IN THE C Appellant § ' V""F v. § AT LAW No 1§ MANUEL CARDENAS, § Appeuee § BEXAR CoUNTY, TEXAs NOTICE OF APPEAL. CERTIFICATIQN. AND REOUEST FOR STAY NOW COMES the State of Texas, by and through Nicholas “Nico” LaHood, Criminal District Attorney of Bexar County, Texas, With the filing of this Notice of Appeal and Request for Stay in the above styled criminal cause.

I. NoTIcE oF APPEAL Pursuam to -Aracle 44.0`1(&)(1) and (a)(s)\ of the rean Code ar criminal Procedure, the State hereby appeals this Court’s order granting the defendant’s Motion to Suppress Evidence and dismissing the information in the above- numbered cause. The order granting the defendant’s Motion to Suppress Evidence and dismissing the case was granted on April 14, 2015. The State"s Notice of Appeal is due to be filed on or before May 4, 2015.

II. CERTIFICATION THAT THE APPEAL Is NoT TAKEN FoR PURPosEs oF DELAY I, Nicholas “Nico” LaHood, Criminal District Attorney of Bexar County, Texas, the prosecuting attorney in this case, hereby certify to this Court. that the appeal in the above styled and numbered cause is not taken for the purpose of delay and that the issues to be presented and evidence suppressed are of substantial importance to the case.

III. REQUEST FoR STAY oF PRoCEEDlNGs IN rim TRlAL CoURT Pursuant to Article 44.01(e) of the Texas Code of Criminal Procedure, the State is entitled to a stay in the proceedings pending the disposition of an appeal under Subsection (a) or (b) of Article 44.01. This appeal is taken pursuant to article 44.01(a) of the Texas Code of Crirninal Procedure. Therefore, the State respectfully requests that this court stay all proceedings in this matter pending disposition of the Statei’s appeal.

Respectfully submitted, &’Waa,» w NI@fioLAs “Nlco” LAHooD f;iminal Diszrz`ct Attorney 'Bexa_r County, Texas West Nueva, Seventh Floor San Antonio~, Texas 78205 Voice: (210) 33 5-2342 Fax: (210)'_335-2884 State Bar No. 2403 03 60 Attorneyfor the State

CERTIFICATE OF SERVICE I, Jennifer D. Rossmeier, Assistant Criminal District Attorney of Bexar County, Texas, hereby certify that a true copy of the above and foregoing Notice of Appeal, Certzfz`catz'on, and Requestfor Stay is being delivered via mail to Robert A.

Valdez, attorney for Defendant/Appellee. raw/uaw ENNIF‘E R D. RossMEIER Assistant Crz'mz`nal District Attomey State Bar No. 24079247 West Nueva, Suite 7 08 San Antonio, Texas 78205 Phone: (210)\ 335-2734 Fax: (210) 335-2436 Email: [email protected] Attomeyfor the State cc: RoBERT A. VALDEZ Atromey at Law State Bar No. 20428000 S. Main, Suite 203 San Antonio, Texas 78204 Voice: (210) 227-2401 Attorneyfor the Defendant/Appellee