ApplicationCal. Super. - 6th Dist.September 29, 202110 11 12 13 14 15 16 17 18 19 20 21 22 23 24 21AP002752 Santa Clara - Civil Tunisia T , , Electronically Filed W1111am Siafgoi‘ii, CA Bar #286948 by Superior Court of CA,PO BOX 3 _ County of Santa Clara, Chlcago, 111111013 60613 on 1/1 0/2022 4.18 PM (847) 744'4903 , Reviewed By: Tunisia Turner saffordlegal@gma11.com Case #21AP002752 Envelo e: 8025909 Attorneyfor Defendant-Appellant Patel p IN THE SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY 0F SANTA CLARA APPELLATE DIVISION PEOPLE 0F THE STATE 0F CALIFORNIA, Case No.: 1-21-AP-002752 Plaintiff and Respondent, (Misdemeanor Case N0. C2105546 ) V. UNOPPOSED [FIRST] APPLICATION FOR EXTENSION 0F TIME; SUPPORTING DECLARATION BY COUNSEL KARTIKEY NIRMALKUMA PATEL, Defendant and Appellant. [ Cal. Rules ofCourt, rule 8.882(b)(3) ] UNOPPOSED [FIRST] APPLICATION FOR EXTENSION 0F TIME T0 THE PRESIDING JUDGE 0F THE APPELLATE DIVISION 0F THE SUPERIOR COURT, THE CLERK 0F THE ABOVE-ENTITLED COURT, THE DISTRICT ATTORNEY, AND ALL INVOLVED COUNSEL: Pursuant t0 California Rules 0f Court, rule 8.882(b)(3), undersigned counsel, on behalf of Defendant-Appellant Kartikey Patel, applies for an extension 0f time, until thir_ty {31) days, or until February 14, 2022, in which t0 complete and file his opening brief. Cause for this request is set forth in the attached Supporting Declaration by Counsel. Respectfully submitted this 10th day 0f January, 2022. By: William Saffor 286948 for Defendant-Appellant Patel APPLICATION FOR EXTENSION OF TIME; DECLARATION Page I Ul'nel' 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 I, WILLIAM SAFFORD, California Bar #286948, under penalty of perjury, declare as follows: 1. 10. 11. Executed this 10th day 0f January, 2022. APPLICATION FOR EXTENSION OF TIME; DECLARATION SUPPORTING DECLARATION BY COUNSEL I am the attorney 0f record for Defendant-Appellant Kartikey Nirmalkuma Patel in Santa Clara County Superior Court Appellate Division matter number 1-21-AP-002752, an appeal taken from a conviction following a change 0f plea in Criminal Division matter number C2105546. Each and every statement herein is true t0 the best of my knowledge and belief, and is based 0n my own review 0f documentation 0r the credible assertions 0f individuals Who have personal knowledge of the facts of this matter. I am submitting this Declaration in support of the Unoggosed [First] Application for Extension ofTime, concurrently filed. By briefing schedule, the opening brief is due January 14, 2022. This is mym request for an extension. The record is not lengthy and the likely issues are not complex. However, before choosing issues for appellate briefing and preparing a brief, I need time to consult With and advise my client, and then d0 further research, so that briefing decisions can reflect his best interests. Accordingly, I am asking for an extension of 31 days, or until February 14, 2022, in which to complete and file an opening brief. Prior to submitting these papers, I conferred With Deputy District Attorney Kaci Lopez regarding the possibility 0f an extension. Ms. Lopez indicated she does not oppose this request. A proposed order, granting the request, is attached as Exhibit A and filed separately. William Safford’ 286948 Page 2 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 EXHIBIT A Proposed Order APPLICATION FOR EXTENSION OF TIME; DECLARATION Page 3 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 IN THE SUPERIOR COURT FOR THE STATE 0F CALIFORNIA COUNTY 0F SANTA CLARA APPELLATE DIVISION PEOPLE 0F THE STATE 0F CALIFORNIA, Plaintiff and Respondent, V. KARTIKEY NIRMALKUMA PATEL, Defendant and Appellant. Upon application by counsel for Appellant Kartikey Patel and for good cause shown, the Court hereby grants the first request for an extension of time t0 file the opening brief. (Cal. Rules of Court, rule 8.882(b)(3).) The opening brief must be filed on 0r before February 14, 2022. It is so ordered. By: // // // SUBMITTED BY: William Safford (286948) for Defendant-Appellant Patel ORDER GRANTING EXTENSION 0F TIME Page 1 Case No.2 1-21-AP-002752 (Misdemeanor Case N0. C2105546 ) [PROPOSED ] ORDER GRANTING EXTENSION 0F TIME Presiding Judge Helen E. Williams 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 CERTIFICATE 0F SERVICE I, the undersigned, am a citizen 0f the United States, over 18 years 0f age, and not a party to the above-entitled action. I hereby certify that, on this 10th day of January, 2022, I caused a true and accurate copy of the foregoing UNOPPOSED [FIRST] APPLICATION FOR EXTENSION 0F TIME and SUPPORTING DECLARATION BY COUNSEL t0 be served upon each of the following, either by electronic service With the consent 0f the party served, or placement With the United States Postal Service in a sealed envelope With postage prepaid, as indicated below: Kaci Lopez, Deputy SANTA CLARA COUNTY DISTRICT ATTORNEY k10pez@dao.sccgov.org m0ti0ns_dropbox@dao.sccgov.org William Saffor 286948 for Defendant-Appellant Patel APPLICATION FOR EXTENSION OF TIME; DECLARATION Page 5