ACCEPTED
03-13-00799-CR
3799017
THIRD COURT OF APPEALS
AUSTIN, TEXAS
1/16/2015 1:37:22 PM
JEFFREY D. KYLE
CLERK
NO.03-13-00799-CR
BILLY JACK VERCHER IN THE
FILED IN
V. 3rd COURT
THIRD COURT OF APPEALS OF APPEALS
AUSTIN, TEXAS
1/16/2015 1:37:22 PM
THE STATE OF TEXAS AUSTIN, TEXAS
JEFFREY D. KYLE
Clerk
STATE'S FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE THIRD COURT OF APPEALS:
NOW COMES the State of Texas, Appellee in the above entitled and numbered
cause and files this First Motion for Extension of Time to File Appellee's Brief, and in
support thereof would show the Court the following:
I.
Appellant was found guilty by a jury of Aggravated Robbery, a First Degree felony
enhanced to a 15-99, and the Judge assessed punishment at 30 years confinement in
the Texas Department of Criminal Justice. Appellant was granted new counsel on June
27,2014. Appellant's brief was filed on December 17,2014. The State's brief is currently
due on January 16, 2015.
II.
The State has not requested an extension in this case prior to this request.
III.
The State requests this extension of time due to the following: Counsel for the
State has been involved in prosecution of felony cases including contested hearings,
pretrial hearings, grand jury presentation, negotiations with opposing counsel, guilty pleas
and other hearings in numerous additional pending felony cases. In addition, the State
has been preparing several jury cases for January 26, 2015.
WHEREFORE, The Attorney for the State requests an extension of thirty (30) days
to February 16, 2015, in which to file State's Brief.
Respectfully submitted,
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Assistant District Attorney
51 st/119th Judicial District
124 W. Beauregard, Suite B
San Angelo, TX 76903
(325) 659-6583
State Bar No. 24072092
SWORN TO AND SUBSCRIBED before me by the said Jason Ferguson, this 16th
day of January, A. D. 2015. ...,~
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Notary Public
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My State of Texas
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June 28, 2016
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Motion for Extension
of Time to File Appellee's Brief was this 16th day of January, 2015, delivered to Melvin
Gray, Attorney for Appellant, through e-file .txcourts.gov