ACCEPTED
05-14-01628-CR
FIFTH COURT OF APPEALS
DALLAS, TEXAS
4/27/2015 10:07:55 AM
LISA MATZ
CLERK
NO. 05-14-01628-CR
TOREY JABBAR NEWHOUSE § IN THE COURT OF APPEALS
FILED IN
5th COURT OF APPEALS
vs. § FOR THE FIFTH DISTRICT
DALLAS, TEXAS
THE STATE OF TEXAS § 4/27/2015
OF TEXAS AT10:07:55
DALLAS AM
LISA MATZ
Clerk
STATE’S FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE JUDGES OF SAID COURT:
THE STATE OF TEXAS, by and through the Criminal District Attorney of
Dallas County, respectfully requests that the time for filing the State’s brief be
extended by thirty (30) days. See TEX. R. APP. P. 38.6(d). In support of this motion,
the State would show the following:
Appellant entered an open plea of guilty to the offense of aggravated robbery
with a deadly weapon, enhanced by a prior felony conviction. The trial court accepted
the plea, deferred adjudication, and placed appellant on community supervision for a
period of ten years. Subsequent, pursuant to the State’s motion, the trial court
adjudicated appellant and sentenced him to twenty-five years’ imprisonment.
Judgment adjudicating guilt was entered on November 25, 2014. After requesting and
receiving an extension, Appellant’s brief was filed on March 27, 2015. The State’s
brief was due, under Rule 38.6(b) of the Texas Rules of Appellate Procedure, on April
26, 2015. This case has not yet been set for submission.
Due to this attorney’s existing docket, the State requests an extension of time of
thirty (30) days, that is up to and including May 26, 2015, in which to file its brief. No
previous extensions have been requested by the State in this case.
WHEREFORE, PREMISES CONSIDERED, the State respectfully requests that
the time for filing its brief be extended until May 26, 2015.
Respectfully submitted,
Susan Hawk Laura Anne Coats
Criminal District Attorney Assistant District Attorney
Dallas County State Bar No. 00790476
Frank Crowley Courts Building
133 N. Riverfront Blvd.,LB19
Dallas, Texas 75207-4399
(214) 653-3625
(214) 653-3643 fax
LAURA.COATS@dallascounty.org
CERTIFICATE OF SERVICE
I hereby certify that a true copy of the foregoing motion was served on Dianne
Jones McVay, Counsel for Appellant, 4303 N. Central Expressway, Dallas, TX 75205
by first class mail and by email at dianne@jonesmcvay.com on April 27, 2015.
Laura Anne Coats
CERTIFICATE OF WORD COMPLAINCE
I hereby certify that the foregoing motion is 390 words in length according to
Microsoft Word, which was used to prepare the brief. See Tex. R. App. P. 73.3; Tex.
R. App. P. 73.1(f).
__________________________________
LAURA ANNE COATS