ACCEPTED
03-14-00516-CR
5392484
THIRD COURT OF APPEALS
AUSTIN, TEXAS
5/22/2015 9:59:06 AM
JEFFREY D. KYLE
CLERK
NO. 03-14-00516-CR
FILED IN
MARK ANTHONY SERRANO IN THE 3rd COURT OF APPEALS
AUSTIN, TEXAS
5/22/2015 9:59:06 AM
v. THIRD COURT OF APPEALS
JEFFREY D. KYLE
Clerk
THE STATE OF TEXAS AUSTIN, TEXAS
STATE'S MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE THIRD COURT OF APPEALS:
NOW COMES the State of Texas, Appellee in the above entitled and
numbered cause and files this Motion for Extension of Time to File
Appellee's Brief, and in support thereof would show the Court the following:
I.
Appellant was found guilty of Theft Over $20,000, a Third Degree
felony enhanced as a Habitual Offender, and the Jury assessed punishment
at 25 years confinement in the Texas Department of Criminal Justice on
June 19, 2014. Appellant filed Notice of Appeal on August 20, 2014.
Appellant's brief was filed on April 22, 2015. Appellant's amended brief was
filed on May 12, 2015. The State's brief is currently due on May 22,2015.
II.
The State has not requested an extension in this case prior to this
request.
III.
The State requests this extension of time due to the following: Counsel
for the State has been preparing for jury trial and is currently trying a
continuous sexual assault of a child case in State v. Miguel Davila, Cause
Number D-14-0826-SA, which began on May 18, 2015. Additionally,
Counsel for the State has been involved in prosecution of cases including
contested hearings, pretrial hearings, grand jury presentation, negotiations
with opposing counsel, guilty pleas and other hearings in numerous
additional pending felony cases.
WHEREFORE, The Attorney for the State requests an extension of
time to July 24,2015, in which to file State's Brief.
John est
Assistant District Attorney
51 st Judicial District
124 W. Beauregard, Suite B
San Angelo, TX 76903
(325) 659-6583
State Bar No. 00796203
SWORN TO AND SUBSCRIBED before me by the said John Best,
this fL-flIJ day of May, A. D. 2015.
{-!::X:::t~
~~~~Yftz',~ CHRISTINE GEORGE
Notary Public. State of Texas
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'\t1;l5.{f..! My Commission Expires Notary Public
··,·7,,70;,'-' ' ' June 28, 2016 State of Texas
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the/oregoing Motion for
Extension of Time to File Appellee's Brief was this t~{t . . day of May, 2015,
delivered to Randol Stout, at rls2700@gmail.com, Attorney for Appellant,
through e-file.txcourts.gov.