ACCEPTED
12-15-00157-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
12/17/2015 10:22:50 AM
Pam Estes
CLERK
No. 12-15-00157-CR
FILED IN
12th COURT OF APPEALS
In the Court of Appeals TYLER, TEXAS
for the Twelfth Judicial District 12/17/2015 10:22:50 AM
at Tyler, Texas PAM ESTES
Clerk
Stanford Jones,
Appellant
V.
State of Texas,
Appellee
On Appeal From Cause No. 2013-0744 in the 217th
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 10-day extension of time to file
its brief.
I.
Under 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. App. P. 38.6(b). Appellant’s Brief was filed on October 15,
2015, giving the State until Monday November 16, 2015 to file its brief.
This Court granted the State a 30-day extension of time in which to file its
brief on November 18, 2015 giving the State until Thursday December 17,
2015 to file its brief.
The State of Texas now requests a 10-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 is working on another brief during this
time period, Jenkins v. State 12-15-00039-CR.
2. Counsel for the State has just returned to work on December
11, 2015 following a medical emergency that occurred on November 2,
2015.
3. Counsel for the State is lead counsel on five felony
sentencing’s, one suppression hearing, and two non-jury trials occurring
between December 14-21, 2015. This is in addition to the normal felony
case load.
4. Counsel for the Appellant is unopposed to this motion,
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 harassment, but to see that justice is done.
Wherefore, Appellee State of Texas prays that the Court grant its
requested 10-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
aperez@angelinacounty.net
Attorney for Appellee
State of Texas
Certificate of Service
I do certify that on December 17, 2015 a true and correct copy of the
above document has been served electronically to John Reeves, 1007
Grant Ave., Lufkin, Texas, 75901, attorney for Appellant, Stanford Jones,
through efile.txcourts.gov.
/s/April Ayers-Perez
Certificate of Conference
I certify that on December 16, 2015, I conferred with John Reeves by
telephone about this motion, and certify that he was unopposed to a 10-day
extension.
/s/April Ayers-Perez