ACCEPTED
03-15-00116-CR
6375344
THIRD COURT OF APPEALS
AUSTIN, TEXAS
8/5/2015 4:47:38 PM
JEFFREY D. KYLE
CLERK
NO. 03-15-00116-CR
COURT OF appeals FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
FOR THE
8/5/2015 4:47:38 PM
JEFFREY D. KYLE
AUSTIN SUPREME JUDICIAL DISTRICT Clerk
CHRISTOPHER QUINN RIVERA,
Appellant
VS.
THE STATE OF TEXAS,
Appellee
APPEAL FROM
THE 428TH JUDICIAL DISTRICT COURT
HAYS COUNTY, TEXAS
TRIAL COURT CAUSE NO. CR-14-0448
First Motion For Extension
of Time in Which to File State's Brief
John Couch
Assistant Criminal District Attorney
712 S. Stagecoach Trail, Suite 2057
San Marcos, Texas 78666
Ph: (512) 393-7600 / Fax: (512) 393-2246
State Bar No. 24048407
john.couch@co.hays.tx.us
Attorney for the State of Texas
TO THE HONORABLE JUSTICES OF THE THIRD COURT OF
APPEALS:
The State files this First Motion for Extension of Time in Which to File
State's Brief, and in support states:
1. The State's current deadline for filing its brief is August 7, 2015.
2. This is the State's first request for an extension of time in which to file
its brief
3. The State respectfully requests an extension of approximately thirty
days, until September 6, 2015 in which to file its brief.
4. Good cause exists for the State's request for extension of time in which
to file its brief The attorney of record is currently the prosecutor in a
felony jury trial.
5. These circumstances have significantly delayed the completion of this
brief
6. This extension is not being sought to cause undue delay, but to seek
justice.
7. For the foregoing reasons, the State respectfully requests that the Court
grant an approximate thirty day extension for filing Appellee's Brief,
until September 6, 2015.
Respectfully submitted,
2/
Jo^ Couch
^
Assistant Criminal District Attorney
Hays County Government Center
712 South Stagecoach Trail, Ste. 2057
San Marcos, Texas, 78666
Tel: 512-393-7600
John.couch@co.hays.tx.us
State Bar No. 24048407
Attorney for the State of Texas
VERIFICATION
The foregoing Appellant Motion for Extension of Time in Which to
File Appellant's Brief was subscribed and sworn to before me by John Couch
onthis ^ ,2015.
John C6uch
Assistant Criminal District Attorney
RHONDA WEDERSTEIN
MY COMMISSION EXPIRES
Sept8mber9,2018
Notary Public in and for the State of Texas
CERTIFICATE OF SERVICE
I certify that on ^ , 2015, I served the above
motion by email to Rickey D. Jones at rickey@satx.rr.com, in accordance
with the Texas Rules of Appellate Procedure.
John 06uch
Assistant Criminal District Attorney