ACCEPTED
06-14-00079-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
NO. 06-14-00079-CR 3/3/2015 2:06:31 PM
DEBBIE AUTREY
CLERK
JUSTIN SANDERS * ON APPEAL FROM THE
Appellant *
FILED IN
* 102ND6th COURT OF
JUDICIAL APPEALS
DISTRICT
TEXARKANA, TEXAS
VS. * 3/3/2015 2:06:31 PM
STATE OF TEXAS * COURT OFDEBBIE
BOWIEAUTREY
COUNTY
Clerk
Appellee * TEXAS
MOTION TO EXTEND LENGTH OF STATE’S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
COMES NOW the State of Texas by and through her below named Assistant Criminal
District Attorney and pursuant to the Texas Rules of Appellate Procedure and hereby requests an
additional 5,000 words to respond to Appellant’s brief and in support of the same would show the
Court as follows:
I.
1. This case is pending from the 102nd Judicial District of Bowie County, Texas. The date of
the judgment is April 2, 2014.
2. The case is styled State of Texas v. JUSTIN SANDERS, Cause Number 13F-1051-102.
3. Appellant was convicted of the offenses of MURDER
4. Punishment was assessed at thirty (30) years in the Institutional Division of the Texas
Department of Criminal Justice and a $5,000 fine.
5. Rule 9.4(i)(2)(B) of the Rules of Appellate Procedure limits a response brief in the court of
appeals to 15,000 words if computer generated.
6. Rule 9.4(i)(4) of the Rules of Appellate Procedure states, “A court may, on motion, permit
a document that exceeds the proscribed limit.”
7. The State requests an extension on the maximum length of State’s Brief for the following
reasons:
The record in this case consists of fifteen (15) volumes.
Appellant filed a brief alleging eight (8) points of error and containing 14, 909 words.
Despite multiple attempts to condense, the incomplete rough draft of the State’s
replies to the eight (8) alleged points of error is currently over 19,000 words including
citations to the law and the record. This rough draft does not yet contain a response to all
arguments made in Appellant’s Brief.
In order to adequately respond to Appellant’s eight (8) alleged points of error along
with the arguments and cases cited within, the State requires additional words beyond the
15,000 word limit proscribed by Rule 9.4(i)(2)(B).
PRAYER
WHEREFORE, on the bases of Rule 9.4 of the Texas Rules of Appellate Procedure, the State
respectfully requests this Court to grant the Motion to Extend Length of State’s Brief.
Respectfully submitted,
/s/ Samantha J. Oglesby
SAMANTHA J. OGLESBY
Texas Bar No. 24070362
601 Main Street
Texarkana, TX 75501
ATTORNEY FOR THE STATE
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing Motion to Extend
Length of State’s Brief was forwarded to Mr. Craig Henry, counsel for Appellant, on this the 3rd day
of March, 2015.
/s/ Samantha J. Oglesby
SAMANTHA J. OGLESBY