ACCEPTED
12-15-00003-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
10/23/2015 8:10:30 PM
Pam Estes
CLERK
Cause No. 12-15-00003-CR
FILED IN
12th COURT OF APPEALS
TYLER, TEXAS
In the Court of Appeals for the
10/23/2015 8:10:30 PM
Twelfth Judicial District at Tyler, Texas PAM ESTES
Clerk
Dequisha Jackson,
Appellant
v.
State of Texas,
Appellee
On Appeal from Cause No. 2013-0731in the 159th
Judicial District Court of Angelina County, Texas
State’s Second Motion for Extension (Unopposed)
To the Honorable Justices of this Court:
Appellee, State of Texas, moves for a 7-day extension of time to file its
brief.
I.
Undre the Texas Rules of Appellate Procedure, the general deadline to file
an appellee’s brief is 30 days after the date the appellant’s brief was filed. Tex. R.
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App. P.38.6(b). Appellant’s Brief was filed on August 24, 2015, giving the State
until Wednesday September 23, 2015 to file its brief. On Wednesday September
23, 2015 the State was granted a 30-day extension of time in which to file its brief,
giving the State until Friday October 23, 2015 to file its brief.
The State of Texas now requests a 7-day extension of time in which to file
its brief.
II.
Good cause exists for allowing the State additional time to file its brief for
the following reasons:
1. Counsel for the State was out of town September 22-25, 2015 at a
prosecutor training conference.
2. Counsel for the State had one felony bench trial and two felony jury
trials during this time frame in which counsel for the State was sole counsel at all
trials: State v. Leviness, Cause No. 2015-0405, State v. Boykin, Cause No. 2015-
0475, and State v. Brown, Cause No. 2015-0163. All three trials took place
between the weeks of October 13-23, 2015 in the 159th Judicial District Court.
3. Counsel for the State was ill and out of the office from September 29-
October 2, 2015.
4. In addition to a normal felony caseload, counsel for the State is
actively working on two other appellate briefs during this same time: Taurus
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Jenkins v. State, Cause No.: 12-15-00039-CR, and Stanford Jones v. State, Cause
No.: 12-15-00157-CR.
5. Counsel for the Appellant is unopposed to this extension.
III.
From the above-listed reasons, the State has demonstrated that good cause
for the failure to be able to submit its brief by the Court’s deadline. This is the
State’s first motion for extension, and it is not brought for purposes of delay or
harrassment, but to see that justice is done.
Wherefore, Appellee State of Texas prays that the Court grant its requested
7-day extension to file its State’s Brief in this matter.
Respectfully Submitted,
/s/ April Ayers-Perez
Assistant District Attorney
Angelina County D.A.’s Office
P.O. Box 908
Lufkin, Texas 75902
(936) 632-5090 phone
(936) 637-2818 fax
State Bar No. 24090975
ATTORNEY FOR THE
STATE OF TEXAS
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Certificate of Service
I certify that on October 23, 2015, a true and correct copy of the above
document has been forwarded to John Reeves, by electronic service through
efile.txcourts.gov.
/s/ April Ayers-Perez
Certificate of Conference
I certify that on October 23, 2015, I conferred with John Reeves about this
motion, and certify that he was unopposed to a 7-day extension.
/s/ April Ayers-Perez
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