ACCEPTED
03-13-00760-CR
4305162
THIRD COURT OF APPEALS
AUSTIN, TEXAS
2/26/2015 4:57:37 PM
JEFFREY D. KYLE
CLERK
No. 03-13-00760-CR
FILED IN
3rd COURT OF APPEALS
IN THE AUSTIN, TEXAS
2/26/2015 4:57:37 PM
JEFFREY D. KYLE
COURT OF APPEALS Clerk
THIRD DISTRICT
AUSTIN, TEXAS
JAMES BROWN,
Appellant
v.
THE STATE OF TEXAS,
Appellee.
SECOND MOTION TO EXTEND TIME FOR FILING APPELLEE'S BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
The State of Texas, by and through the District Attorney for Travis County,
respectfully moves this Court to extend the time for filing Appellee's brief. In
support of this motion, the State respectfully shows the Court as follows:
Appellee's brief in this cause is due on Friday, February 27, 2015. Appellee
has requested one prior extension to file Appellee's brief. Appellee respectfully
requests an extension of seven days until March 6, 2015.
Counsel’s recent trial schedule, including a jury trial February 23 – 24 with an
ensuing sentencing hearing February 27, and other routine courthouse duties have
1
interfered with completion of the brief which is perhaps seventy-five percent
complete. Only a brief time extension is necessary for completion.
PRAYER
For these reasons, the State requests the Court to grant this motion to extend
the time for filing Appellee's brief until March 6, 2015.
Respectfully submitted,
ROSEMARY LEHMBERG
DISTRICT ATTORNEY
TRAVIS COUNTY, TEXAS
/s/ William G. Swaim III
Special Assistant District Attorney
State Bar No. 00785074
P.O. Box 1748
Austin, Texas 78767
Phone (512) 854-9637
Fax No. (512) 854-9316
Bill.Swaim@traviscountytx.gov
2
CERTIFICATE OF COMPLIANCE
Pursuant to Texas Rule of Appellate Procedure 9.4(i), I hereby certify, based
on the computer program used to generate this motion, that this motion contains 343
words, excluding words contained in those parts of the brief that Rule 9.4(i) exempts
from inclusion in the word count.
/s/ William G. Swaim III
Special Assistant District Attorney
CERTIFICATE OF SERVICE
I certify that, on this the 26th day of February, 2015, a copy of the foregoing
motion was sent, via U.S. mail, email, or electronically through the electronic file
manager, to the following attorney for the appellant:
Tanisa Jeffers, Esq. Brian
Bernard, Esq. Bernard &
Associates 1203 Baylor
Street Austin, TX 78703
Fax: 512.478.9827
Email: tanisaL@hotmail.com
attorneybernard@yahoo.com
/s/ William G. Swaim III
Special Assistant District Attorney
3