PD-00013-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 4/2/2015 11:58:17 AM April 2, 2015 Accepted 4/2/2015 12:49:22 PM ABEL ACOSTA NO. 00013-­‐15 CLERK

THE STATE OF TEXAS

§ IN THE COURT OF

V.

§ CRIMINAL APPEALS

MICHAEL ERIC RENDON § AUSTIN, TEXAS

APPELLEE’S MOTION FOR AN EXTENSION OF TIME TO FILE APPELLEE’S BRIEF ON STATE’S PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE COURT OF CRIMINAL APPEALS:

Now comes, Edward F.

Shaughnessy, III, attorney at law, attorney

for the appellee, Michael Eric Rendon, and files this Appellee’s Motion

for an Extension of Time to File Appellee’s Brief on State’s Petition for

Discretionary Review.

In support of the instant motion the Appellee

would show unto the court the following:

A.

The appellant was charged by way of indictments returned by a

Victoria County grand jury with the offenses of Money Laundering and

Possession of a Marijuana in cause numbers 12-­‐8-­‐26805-­‐D & 12-­‐8-­‐ 0026806-­‐D.

Following a pre-­‐trial motion to suppress evidence the trial Court entered an order granting the defendant’s motion to suppress.

Notice of appeal was filed by the State of Texas and an appeal was

pursued to the Court of Appeals.

The judgment of the trial Court was

affirmed on direct appeal and a petition for discretionary review was

granted to the State of Texas.

The State’s brief was filed in this Court on

March 3’ 2015.

The appellee’s brief is due to be filed with this Court on

April 2, 2015.

The appellee respectfully requests a thirty day extension

of time to file the appellee’s brief until May 2, 2015.

B.

The appellee is seeking an extension of time to file the instant for

the first time; no previous extensions of time have bee sought by the

appellee.

C.

The undersigned counsel is representing the appellee in this

matter without having previously been involved in this matter.

The

undersigned’s representation originated with the filing of the

appellant’s brief in this Court.

D.

The undersigned is presently in the process of compiling briefs

on the behalf of the State of Texas in the cases of Jennifer Pena v. The

State of Texas, Cause no. 13-­‐14-­‐00291-­‐CR; Felix Villarreal v. The State of

Texas, Cause no. 13-­‐15-­‐00014-­‐CR and Chad Ballard v. The State of

Texas, Cause No. 04-­‐14-­‐00603-­‐CR.

In addition the undersigned is in the

process of filing briefs on behalf of the appellant in the cases of Jordan

Lewis v. The State of Texas, Cause no. 01-­‐14-­‐00557-­‐CR.

E.

Counsel has recently filed briefs on behalf of the appellee in the

cases of Lawrence Steele Terrill v. The State of Texas, Cause No. 04-­‐14-­‐ 00571-­‐CR and Edgar Javier Gonzales v. The State of Texas, Cause No.

04-­‐14-­‐00100-­‐CR.

F.

The undersigned recently filed a brief on behalf of the appellant in

the case of Ex Parte Greg Saul, Cause Number 04-­‐15-­‐00093-­‐CR.

G.

Counsel is scheduled to begin a jury trial in the 290th District

Court of Bexar County on April 6, 2015 in the case of The State of Texas v. Roland Aguiar, cause no. 2014-­‐CR-­‐10164 wherein the defendant is

charged with the offense of Murder.

CONCLUSION AND PRAYER

Wherefore premises considered the appellee in the instant case

would respectfully request that this Court grant the instant motion and

extend the time for the filing of the appellee’s brief until May 4, 2015.

___/s/Edward F. Shaughnessy___________ Edward F.

Shaughnessy, III E.

Locust San Antonio, Texas 78212 (210) 212-­‐6700 (210) 212-­‐2178 (fax) SBN 18134500 [email protected]

CERTIFICATE OF SERVICE

I, Edward F.

Shaughnessy, III, hereby certify that a true and

correct copy of the instant motion was mailed to Stephen B.

Tyler,

attorney for the appellant at N.

Bridge St. Suite 301, Victoria, Texas

77901, on this the 31st day of March, 2015.

__/s/Edward F. Shaughnessy______ Edward F.

Shaughnessy, III