ACCEPTED
06-14-00115-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
3/20/2015 1:44:03 PM
DEBBIE AUTREY
CLERK
CAUSE NO. 06-14-00115-CR
CORDERO BROWN § IN THE COURT OF APPEALS
FILED IN
6th COURT OF APPEALS
§ TEXARKANA, TEXAS
VS. §IN AND FOR THE 3/20/2015
SIXTH 1:44:03
DISTRICT
PM
§ DEBBIE AUTREY
THE STATE OF TEXAS § OF THE STATEClerk
OF TEXAS
STATE'S FIRST MOTION TO EXTEND TIME
FOR FILING STATE’S BRIEF
THE STATE OF TEXAS, by and through the undersigned Assistant District
Attorney, respectfully moves the Court to extend the time for filing of the
Appellee’s Brief in accordance with Rule 10.5 of the Texas Rules of Appellate
Procedure. In support of its motion, the State respectfully offers the following:
1. The Appellee’s brief is due Monday, March 23, 2015, and I have not completed
it due to other matters with more pressing deadlines.
2. The State seeks an additional 30 days, until Wednesday, April 22, 2015. The
undersigned will, nonetheless, attempt to complete and file the State’s brief
prior to the extended deadline.
3. The undersigned attorney is responsible for all post-conviction prosecution for
the Gregg County Criminal District Attorney’s Office, including direct appeals,
appeals from justice courts, and applications for habeas corpus.
In the past 30 days the undersigned attorney has completed the following:
A. Appellate Briefs:
1. March 4, 2015, Kelly v. State, PD 0702-13
B. Responses to Writ Applications:
1. Ex parte Larry Means 42561-B-H-?
WR-16,525-07, February 25, 2015
2. Ex parte Ryan Woods, 39,923B H 1, WR 37,856-10, March
13, 2015
3. Ex parte Terry Miller 30,600-A-H-8, WR 37,856-11 March
16, 2015.
C. PDR’s reviewed:
1. Palmer v. State, 6-13-00265-CR, February 12, 2015.
2. Thomas v. State, 6-14-00002-CR, February 13, 2015.
In the next 30 days the undersigned attorney must respond to the following
in addition to this brief:
A. Appellate Briefs due:
1. Ross v. State, 06-14-00157-CR April 10, 2015
B. Due dates for responses, if any, to PDR, after no extensions
1. Saddler v. State, 06-14-00175-CR, requested due date:
March 23, 2015.
C. Habeas responses due:
1. Ex parte Cline 16,318-A-H-12?, WR-16.199-02, March
30, 2015
2. Ex parte Moises Rentaria 38,802-A-H-1 March 31, 2015
3. Ex parte Ladderick Morgan 33,311-B-H-1 March 31,
2015.
4. Ex parte James Pierce 37,630 A-H-3 March 31, 2015
4. Appellant relies on the following facts as good cause for the requested
extension:
a. During the past 30 days, the undersigned has submitted an appellate brief,
and four habeas responses, as shown above.
b. I have also read the brief and the 10-volume record in this case, but I have
not finished writing the brief.
c. No previous extensions have been requested by the State in this case.
d. This extension is not requested for purposes of delay, but so that justice may
be done.
Respectfully submitted,
/s/Zan Colson Brown
Zan Colson Brown
Texas Bar No. 03205900
Assistant Criminal District Attorney
101 East Methvin St., Suite 333
Longview, TX 75601
Telephone: (903) 236–8440
Facsimile: (903) 236–3701
E-mail: zan.brown@co.gregg.tx.us
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the above and foregoing has been
forwarded to appellant by e-service addressed to Mr. Lew Dunn at
dunn@texramp.com.
This 20th day of March, 2015.
/s/ ZanColsonBrown
Zan Colson Brown
Assistant Criminal District Attorney