ACCEPTED
06-14-00157-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
4/10/2015 11:35:12 AM
DEBBIE AUTREY
CLERK
CAUSE NO. 06-14-00157-CR
CINQUE ROSS § IN THE COURT OF APPEALS
FILED IN
6th COURT OF APPEALS
§ TEXARKANA, TEXAS
VS. §IN AND FOR THE 4/10/2015
SIXTH 11:35:12
DISTRICT
AM
§ DEBBIE AUTREY
THE STATE OF TEXAS § OF THE STATE OF ClerkTEXAS
STATE'S FIRST MOTION TO EXTEND TIME
FOR FILING STATE’S BRIEF
TO THE HONORABLE JUDGE OF SAID COURT:
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 today, April 10, 2015, and I have not completed it
due to other matters with more pressing deadlines.
2. The State seeks an additional 31 days, until Monday, May 11, 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
and applications for habeas corpus, bond forfeitures and traffic citation appeals.
In the past 30 days the undersigned attorney has worked on the following:
A. Appellate Brief
1. Cordero Brown v. State, 06-14-00115-CR, (10 volumes; 5
issues) April 22, 2015 after one extension .
B. Responses to Six Writ Applications:
1. Ex parte Ryan Woods, 39,923B H 1, WR 37,856-10, March 13,
2015
2. Ex parte Terry Miller 30,600-A-H-8, WR 37,856-11 March 16,
2015.
3. Ex parte Laderick Morgan 33,311-B-H-1 March 31, 2015.
4. Ex parte Moises Renteria 38,802-A-H-1 April 1, 2015.
5. Ex parte James Pierce 37630-A.H-3 April 1, 2015.
6. Ex parte Cline 16,318-A-H-12?, WR-16.199-02, March 30, 2015
C. PDR’s reviewed:
1. Saddler v. State, 6-14-00016-CR, March 23, 2015.
2. Pruitt v. State, 6-14-00216-CR, March 30, 2015.
4. In the next 30 days the undersigned attorney has briefing deadlines in the
following cases in addition to this one:
A. Brown v. State, 06-14-00115-CR;
(10 volumes; 5 issues) April 22, 2015 after one extension
B. Nelson v. State, 06-14-00204-CR, April 20, 2015
5. Appellant relies on the following facts as good cause for the requested
extension:
A. During the past 30 days, the undersigned has submitted seven habeas
responses, as shown above, and has worked on the Brown brief. In
addition, I have processed numerous traffic court appeals and bond
forfeiture cases.
B. No previous extensions have been requested by the State in this case.
C. 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 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 all counsel of record by electronic transmission to:
Mr. Lew Dunn
P.O. Box. 2226
Longview, Texas 75606
Dunn@texramp.net
This 10th day of April, 2015.
/s/ ZanColsonBrown
Zan Colson Brown
Assistant District Attorney