ACCEPTED
04-14-00904-cr
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
11/13/2015 3:50:25 PM
KEITH HOTTLE
CLERK
No. 04-14-00904-CR
IN THE COURT OF APPEALS
FILED IN
FIRST COURT OF APPEALS DISTRICT OF TEXAS 4th COURT OF APPEALS
HOUSTON, TEXAS SAN ANTONIO, TEXAS
11/13/15 3:50:25 PM
____________________________________________________________
KEITH E. HOTTLE
JOHNATHAN MATTHEW ESCOBEDO, Clerk
Appellant
v.
THE STATE OF TEXAS,
Appellee
______________________________________________________________________________
On Appeal from the 81st/218th District Court
Atascosa County, Texas
Cause Number 13-09-0117-CRA
______________________________________________________________________________
STATE’S MOTION FOR EXTENSION
OF TIME TO FILE BRIEF
______________________________________________________________________________
Rene M. Pena
District Attorney
81st JUDICIAL DISTRICT OF TEXAS
Marc Ledet
Assistant District Attorney
81st / 218th JUDICIAL DISTRICT OF TEXAS
1327 3RD STREET
Floresville, Texas 78026
Tele: (830) 393-2200
Fax: (830) 393-2205
E-Mail: marcledet@81stda.org
State Bar No. 24002459
Attorneys for the State of Texas
STATE’S FIRST MOTION FOR EXTENSION
OF TIME TO FILE BRIEF
The State of Texas, under the authority of Rules 10.5(b) and 38.6(d), Texas Rules
of Appellate Procedure asks the Court to extend time to file the State’s Brief from
NOVEMBER 13, 2015, up to and including NOVEMBER 20, 2015, a period of seven (7)
days.
1. Appellant was found guilty in Atascosa County, Texas for Murder.
2. The State’s Brief is presently due on NOVEMBER 13, 2015.
3. The State of Texas respectfully requests an additional seven (7) days to file its
brief, that is, an extension of time until November 20, 2015.
4. Only one previous extension has been requested by the State, and this its second\
and last extension, is only for 7 days more.
5. The State of Texas requests this extension based on the following reasons:
A. The 81st Judicial District Attorney’s Office covers five (5) counties and
over two hundred miles. Our office does not have an appellate section.
All appellate work is done at times when prosecutors are not in court, not
preparing for trial, or not preparing for grand jury.
B. The State was delayed in receiving a copy of Appellant’s brief and also has
a special Grand Jury scheduled for Monday, November 16, 2106.
C. For these reasons, the State asks the Court to grant an extension of thirty
(30) days to November 13, 2015, within which the State may file its brief
in this cause.
Respectfully submitted,
Rene M. Pena
District Attorney
81st JUDICIAL DISTRICT OF TEXAS
TEXAS BAR NUMBER 00792752
/S/ MARC LEDET
Marc Ledet
Assistant District Attorney
81st JUDICIAL DISTRICT OF TEXAS
1327 3RD STREET
Floresville, Texas 78026
Telephone (830) 393-2200
Telecopier (830) 393-2205
TEXAS BAR NUMBER 24002459
Attorneys for the State of Texas
Certificate of Service
I hereby certify that the above and foregoing was sent to Richard Langlois, 217
Ardent Grove, San Antonio, TX 78215 on the 13th day of November, 2015 in accordance
with the Texas Rules of Procedure.
/S/ Marc Ledet