PD-0469&0470&0471&0472-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 10/16/2015 12:13:11 PM
October 16, 2015 Accepted 10/16/2015 12:34:09 PM
ABEL ACOSTA
IN THE CLERK
COURT OF CRIMINAL APPEALS
JOHN B. ISBELL, §
APPELLANT §
V. § NO. PD-0469-15
§
THE STATE OF TEXAS, §
APPELLEE §
STATE’S MOTION TO EXTEND TIME TO FILE
BRIEF ON THE MERITS
COMES NOW the State of Texas, by and through Sharen Wilson, the
Tarrant County Criminal District Attorney and files this motion to extend the time
to file the State’s Brief on the Merits.
I.
On September 16, 2015, this Court granted the State’s Petition for Review
of a decision by the Second Court of Appeals in Isbell v. State, No.
02-14-00124(-127)-CR, 2015 WL 1407749 (Tex. App.—Fort Worth March 26,
2015) (mem op., not designated for publication).
II.
The current deadline for filing the State's brief is October 16, 2015. The
State now requests an extension of 30 days (until November 16, 2015) to file the
State’s brief. The State has not previously requested an extension of time to file
this brief.
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III.
This extension is not for the purposes of delay, but rather so that
undersigned counsel may adequately set forth the State’s position in its grounds for
review. The undersigned has been working not only on this brief, but on the State’s
reply briefs in Ervin v. State, No. 08-15-00025-CR and Davis Logan v. State, No.
02-15-00140-CR.
Wherefore, the State prays that the Court grant an extension of 30 days to
November 16, 2015 for filing the State’s brief on the merits.
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Respectfully submitted,
SHAREN WILSON
Criminal District Attorney
Tarrant County, Texas
DEBRA WINDSOR
Assistant Criminal District Attorney
Chief, Post-Conviction
Tarrant County, Texas
/s/ James Gibson_____________
JAMES GIBSON, Assistant
Criminal District Attorney
401 W. Belknap Street
Fort Worth, Texas 76196-0201
(817) 884-1687
FAX (817) 884-1672
State Bar No. 00787533
COAAppellateAlerts@TarrantCounty.com
CERTIFICATE OF SERVICE
A copy of the State's Motion to Extend Time to File Brief on the Merits has
been e-served to opposing counsel, the Hon. Barry G. Johnson, Barrygj@aol.com,
2821 E. Lancaster, Fort Worth, Texas 76103, on October 16, 2015.
/s/ James Gibson
JAMES GIBSON
H:\GIBSON.G17\MOTIONS\Isbell; ext to file pdr.docx
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