ACCEPTED
03-14-00094-CR
4054594
THIRD COURT OF APPEALS
AUSTIN, TEXAS
2/6/2015 1:28:40 PM
JEFFREY D. KYLE
CLERK
NO. 03-14-00094-CR
WILLIAM ALBERT MOWER § IN THE COURT OF APPEALS
FILED IN
3rd COURT OF APPEALS
§ AUSTIN, TEXAS
v. § THIRD DISTRICT
2/6/2015 1:28:40 PM
§ JEFFREY D. KYLE
Clerk
STATE OF TEXAS § AUSTIN, TEXAS
MOTION FOR EXTENSION OF TIME TO FILE BRIEF
NOW COMES THE STATE OF TEXAS, Appellee, by and through her
Assistant District Attorney, and moves the Court, pursuant to Texas Rule of Appellate
Procedure 38.6(d), to extend the deadline for filing the State’s brief. In support of its
motion, the State would show the Court the following:
1. The State’s Brief in this case is due on February 6, 2015.
2. The State has requested and this court has granted one previous extension.
3. As detailed in the previous motion for extension, the undersigned Assistant District
Attorney, assumed the duties of the appellate prosecutor for the Williamson County
District Attorney’s Office on November 3, 2014, and thereupon found
approximately sixteen writs of habeas corpus unaddressed and unresolved, as well
as numerous motions and procedural appellate matters that were unresolved.
4. The undersigned is the sole Assistant District Attorney in the Williamson County
District Attorney’s Office assigned to the appellate division, and must, in addition
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to handling writs and direct appeals, advise the trial prosecutors on motions to
suppress, jury charges, issues that arise during trial, and other legal matters as they
come up during the course of the prosecution of a case.
5. During the time given to prepare the State’s brief in this matter, the undersigned
Assistant District Attorney has filed findings of fact and conclusions of law in Ex
Parte Stephen Farrell Eikelboom, WR-81,534-01, WR-81,534-02, WR-81,534-03,
and Ex Parte Antonio Gonzalez Rodriguez 00-430-K368B, obtained and filed an
affidavit requested by the Court of Criminal Appeals in Ex Parte Cory Dale
Morgan WR-81,867-01, 12-1212-K368A, and filed a State’s Response to
Appellant’s Motion to Dismiss in State vs. Wachtendorf, 03-14-00633-CR.
6. For the foregoing reasons, The State respectfully requests that the deadline for
filing its brief in the above stated cause be extended for an additional sixty (60)
days from the current due date of February 6, 2015, to April 7, 2015.
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WHEREFORE, PREMISES CONSIDERED, the State of Texas respectfully
requests that this Court grant its motion for an extension of time and extend the State’s
deadline to file its brief to April 7, 2015.
Respectfully submitted,
Jana Duty
District Attorney
Williamson County, Texas
/s/ John C. Prezas
John C. Prezas
Assistant District Attorney
State Bar Number 24041722
405 Martin Luther King #1
Georgetown, Texas 78626
(512) 943-1248
(512) 943-1255 (fax)
jprezas@wilco.org
Certificate of Service
This is to certify that on February 6, 2015, a copy of the foregoing motion has
been sent to Appellant’s attorney of record, Ms. Kristen Jernigan, 207 S. Austin Ave.
Georgetown, Texas 78626, by eservice via her email address of record
kristen@txcrimapp.com.
/s/ John C. Prezas
John C. Prezas
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