Willie Frank Jackson v. State

ACCEPTED 06-14-00097-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 4/13/2015 4:05:41 PM DEBBIE AUTREY CLERK CASE NO. 06-14-00097-CR In The FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS COURT OF APPEALS 4/13/2015 4:05:41 PM SIXTH DISTRICT OF TEXAS DEBBIE AUTREY AT TEXARKANA Clerk WILLIE FRANK JACKSON, Appellant VS. THE STATE OF TEXAS, Appellee On Appeal from the 354th Judicial District Court of Hunt County, Texas Trial Court Cause No. 29,295 Honorable Richard A. Beacom, Jr., Judge Presiding MOTION FOR EXTENSION OF TIME TO FILE STATE'S BRIEF NOBLE DAN WALKER, JR. District Attorney, in and for Hunt County, Texas KELI M. AIKEN Assistant District Attorney State Bar Number- 24043442 P.O. Box 441 4th Floor, Hunt County Courthouse Greenville, Texas 75401 Telephone Number- (903) 408-4180 Facsimile Number- (903) 408-4296 kaiken@huntcounty.net MOTION FOR EXTENSION OF TIME TO FILE STATE'S BRIEF Comes now, The State of Texas, and files this, her Motion for Extension of Time to File State's Brief. I. The current filing deadline for the State's brief was March 23, 2015. II. The State requests permission to file a brief by April 24, 2015. Ill. The State requests an extension because a new prosecutor has taken over this case and will need time to review the record to respond to the appeal. The prosecutor who handled this trial is no longer with our office. After the prior assistant left the office, we discovered that no response was filed in this case. We obtained a copy of the record as of Friday, April 10, 2015 and are working to respond to the appeal. IV. The State has made no previous requests for extensions to file her brief. V. The Appellant is not going to file an opposition to this motion. VI. For the reasons stated hereinabove, it is respectfully requested that this Court grant the State of Texas until April 24, 2015, to file her brief. Respectfully submitted, Is/ Keli M. Aiken Keli M. Aiken Assistant District Attorney Hunt County, Texas P.O. Box 441 Greenville, Texas 75403-0441 Phone: 903/408-4180 Fax: 903/408-4296 kaiken@huntcounty.net CERTIFICATE OF CONFERENCE I certify that I conferred by telephone with Mr. Jason Duff today, April 13, 2015, regarding this motion, and Mr. Duff courteously agreed stated he would not file a motion in opposition to our request. Is/ Keli M. Aiken Keli M. Aiken CERTIFICATE OF SERVICE This is to certify that a true copy of this Motion to Extend Time to File State's Brief has been forwarded to Mr. Jason Duff on April 13, 2015 by placing the copy in his box in the Hunt County District Clerk's office per local rules. Is/ Keli M. Aiken Keli M. Aiken