Court of Civil Appeals of Texas, 2015

Jonathan Jose Guillen v. State

Court of Civil Appeals of Texas · Decided October 16, 2015

Opinion

ACCEPTED 04-14-00772-CR FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 10/16/2015 2:56:35 PM KEITH HOTTLE CLERK NO. 04-14-00772-CR § IN THE FOURTH DISTRICT JONATHAN JOSE GUILLEN § § VS. § COURT OF APPEALS § § 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.

On October 9, 2014, a jury found Appellant guilty of murder. On October 14, 2014, the jury sentenced Appellant to 99 years in the Texas Department of Criminal Justice, Institutional Division. Appellant filed a notice of appeal on November 3, 2014. Appellant filed a Motion for New Trial on November 12, 2014 and it was denied by the trial court on November 18, 2014. The reporter’s record was filed on April 28, 2015. Appellant filed his brief on August 17, 2015. After a first extension of time, the State’s brief was due October 16, 2015. This is the State’s second motion requesting an extension of time and the State requests a 30 day extension to November 16, 2015.

1 of 3 This extension is not sought for the purpose of delaying this appeal. The State requests an extension for the following reasons: 1) Counsel would like more time to thoroughly read the record in this case, as well as to research and write the State’s brief. The reporter’s record in this case is voluminous and consists of fourteen volumes.

2) Counsel recently filed the following briefs in the Fourth Court of Appeals: a. State of Texas v. Charles Caves, No. 04-15-00367-CR. b. In the Interest of C.F.N., A Child, No. 04-15-00458-CV.

Therefore, counsel respectfully asks the Court to grant this extension of 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 November 16, 2015 for filing the State’s brief.

Respectfully submitted,

Nicholas “Nico” LaHood Criminal District Attorney Bexar County, Texas /s/ Jennifer Rossmeier Brown ____________________ Jennifer Rossmeier Brown State Bar No. 24079247 Assistant Criminal District Attorney W. Nueva Street San Antonio, Texas 78205-3030 Phone: (210) 335-2734 Fax: (210) 335-2436 Email: [email protected]

2 of 3 CERTIFICATE OF SERVICE I certify that a true copy of the above was served on the attorney of record in accordance with the Texas Rules of Appellate Procedure on October 16, 2015, in the manner described below:

Via Electronic Service Alex J. Scharff E. Main Plaza San Antonio, Texas 78205 [email protected] Via Electronic Service Alan Brown Main Plaza E San Antonio, Texas 78205 [email protected]

/s/ Jennifer Rossmeier Brown

3 of 3

Case-law data current through December 31, 2025. Source: CourtListener bulk data.