ACCEPTED
04-14-00688-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
3/17/2015 10:48:06 AM
KEITH HOTTLE
CLERK
NO. 04-14-00050-CR and 04-14-00688-CR
TAYLOR RAE ROSENBUSCH § IN THE FOURTH DISTRICT
FILED IN
4th COURT OF APPEALS
§ SAN ANTONIO, TEXAS
§ 3/17/2015 10:48:06 AM
VS. § COURT OF APPEALSKEITH E. HOTTLE
§ Clerk
§
STATE OF TEXAS § SAN ANTONIO, TEXAS
MOTION FOR EXTENSION OF TIME
TO FILE STATE’S BRIEF
TO THE HONORABLE JUDGES OF THE FOURT COURT OF APPEALS:
NOW COMES Nicholas “Nico” LaHood, Criminal District Attorney of
Bexar County and Counsel for the State of Texas, and files this Motion asking that
the Court extend the time for filing the State’s brief.
Appellant was found guilty on two charges of intoxication manslaughter.
She was sentenced to 12 years in prison on October 18, 2013. A motion for a new
trial was timely filed on November 15, 2013. The notice of appeal was filed on
January 14, 2014. The reporter’s record was filed on December 10, 2014.
Appellant filed her brief on February 10, 2015. The State’s brief was due March
12, 2015. This is the State’s first motion for extension and the State requests a 30
day extension to April 13, 2015.
This extension is not sought for the purpose of delaying this appeal. State
requests an extension for the following reasons:
1) Counsel would like more time to research and write the State’s brief.
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2) Counsel was out of town from March 9-11 2015.
3) Counsel is currently working on the following brief:
a. Kayela McClintick v. State, 04-14-00645CR
4) Counsel recently filed the following brief in the First Court of Appeals:
a. Roland Alvarado v. State, 01-14-00547-CR
5) Counsel recently filed the following briefs in the Fourth Court of
Appeals:
a. Andres Juarez v. State, 04-14-00372-CR
b. Paulino Flores v. State, 04-14-00315-CR
c. In re J.B., 04-14-0079-CV
d. Filiberto Sierra v. State, 04-14-00279-CR
a. In re K.B.F. and Z.A.R., 04-14-004392-CV
b. Frances Rosalez Ford v. State, 04-14-00025-CR
c. Mark Anthony Garcia v. State, 04-13-00818-CR
d. Arthur Thomas v. State, 04-14-00025-CR
Therefore, counsel respectfully asks the Court to grant this extension time
to file the State’s brief in this case.
WHEREFORE, PREMISES CONSIDERED, Counsel for the State prays
that the Court grant an extension of time to April 13, 2015 for filing the State’s
brief.
Respectfully submitted,
Nicholas “Nico” LaHood
Criminal District Attorney
Bexar County, Texas
/s/ Lauren A. Scott
_____________________
Lauren A. Scott
State Bar No. 24066843
Assistant Criminal District Attorney
101 W. Nueva Street
San Antonio, Texas 78205-3030
Phone: (210) 335-2885
Email: lscott@bexar.org
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CERTIFICATE OF SERVICE
I, Lauren A. Scott, Assistant District Attorney, Bexar County, Texas, certify
that a copy of the foregoing motion was delivered by e-file e-service to John F.
Carroll, attorney for appellant, on March 17, 2015.
_/s/ Lauren A. Scott
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