PD-0526-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 10/14/2015 5:05:11 PM October 14, 2015 Accepted 10/14/2015 5:09:15 PM ABEL ACOSTA No. PD-0526-15 CLERK

IN THE COURT OF CRIMINAL APPEALS OF THE STATE OF TEXAS

THE STATE OF TEXAS, Appellant v. VICTOR MANUEL SCHUNIOR, JR., Appellee

* * * * * STATE’S UNOPPOSED MOTION TO EXTEND TIME FOR FILING ITS BRIEF * * * * *

ISIDRO R. ALANIZ DISTRICT ATTORNEY 49th Judicial District By: DAVID L. REUTHINGER, JR. Assistant District Attorney, Bar I.D. No. 24053936 No. PD-0526-15

IN THE COURT OF CRIMINAL APPEALS OF THE STATE OF TEXAS

THE STATE OF TEXAS, Appellant v. VICTOR MANUEL SCHUNIOR, JR., Appellee

* * * * * STATE’S UNOPPOSED MOTION TO EXTEND TIME FOR FILING ITS BRIEF * * * * * TO THE HONORABLE COURT OF CRIMINAL APPEALS: Comes now the State of Texas, by and through its Assistant District Attorney, and respectfully submits to the Court its motion to extend the time for filing its brief to and including the 2nd day of November, 2015, and would show the Court the following: On September 9, 2015, this Court granted the undersigned attorney’s petition for discretionary review in this case. Due to other cases that were pending in the Fourth Court of Appeals, additional time is required to complete the brief in this case. The State’s brief is timely if filed on or before October 16, 2015, and fifteen additional business days should be sufficient to finish it. The following business day is November 2, 2015. No previous motions to extend the deadline for filing this brief have been filed. On October 14, 2015, the undersigned attorney contacted Roberto Balli, Attorney for the Appellee, via email, and he stated that he had no opposition to this request for an extension of time.

WHEREFORE, the State prays that its motion to extend the time for filing its brief until November 2, 2015, be granted.

Respectfully submitted, ISIDRO R. ALANIZ DISTRICT ATTORNEY 49th Judicial District By: ___/s/____________ David L. Reuthinger, Jr. Assistant District Attorney for THE STATE OF TEXAS Webb and Zapata Counties, 49th Judicial District 1110 Victoria St., Suite 401 Laredo, Texas 78040 (956) 523-4900 (956) 523-5070 (Fax) Bar No. 24053936 [email protected] ATTORNEY FOR APPELLANT CERTIFICATE OF SERVICE A copy of the foregoing State’s Motion to Extend the Time for Filing its Brief has been e-served on October 14, 2015 to: * Roberto Balli, Attorney for Appellee, at [email protected].

* The State Prosecuting Attorney, [email protected].

___________________/s/____________ DAVID L. REUTHINGER, JR.