ACCEPTED
06-15-00201-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
7/6/2016 10:52:07 AM
DEBBIE AUTREY
CLERK
CAUSE NO. 06-15-00201-CR
SERGIO RASHAD FONZA-CAREY § IN THE COURT OF APPEALS
FILED IN
6th COURT OF APPEALS
§ TEXARKANA, TEXAS
VS. § FOR THE SIXTH
7/6/2016 DISTRICT
10:52:07 AM
§ DEBBIE AUTREY
THE STATE OF TEXAS § OF THE STATEClerkOF TEXAS
STATE'S FIRST MOTION TO EXTEND TIME
FOR FILING STATE’S BRIEF
THE STATE OF TEXAS, by and through the undersigned Assistant District
Attorney, respectfully moves the Court to extend the time for filing of the
Appellee’s Brief in accordance with Rule 10.5 of the Texas Rules of Appellate
Procedure. In support of its motion, the State respectfully offers the following:
1. The Appellee’s brief is due July 7, 2016, and I have not completed it. This is the
State’s first motion to extend time in this case.
2. The State seeks an additional 32 days, until August 8, 2016. The undersigned
will nevertheless attempt to complete and file the State’s brief prior to the
extended deadline.
3. The undersigned attorney is responsible for all post-conviction prosecution for
the Gregg County Criminal District Attorney’s Office, including direct appeals
and applications for habeas corpus, bond forfeitures and traffic citation appeals.
In the past 30 days the undersigned attorney has worked on the following:
A. Appellate briefs:
Garcia v. State 06-15-00187, filed on June 21
State v. Reel 06-15-00230-CR filed on June 28
4. In the next thirty days, Appellee also has one more brief due in this court:
State v. Strube, 06-15-00185-CR due July 21.
5. In addition, the undersigned attorney was out of town from June 22-24, and
will be out of state from July 12-14.
6. Appellant relies on the above facts as good cause for the requested
extension.
7. This extension is not requested for purposes of delay, but so that justice may
be done.
Respectfully submitted,
/s/Zan Colson Brown
Zan Colson Brown
Texas Bar No. 03205900
Assistant District Attorney
101 East Methvin St., Suite 333
Longview, TX 75601
Telephone: (903) 236–8440
Facsimile: (903) 236–3701
E-mail: zan.brown@co.gregg.tx.us
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the above and foregoing has been
forwarded to all counsel of record through Texas e-file.com
Mr. Clement Dunn
140 E, Tyler Street, Suite 240
Longview, Texas 75601
clementdunn@aol.com
This 6th day of July, 2016.
/s/ ZanColsonBrown
Zan Colson Brown
Assistant District Attorney