ACCEPTED
03-15-00265-CR
6629169
THIRD COURT OF APPEALS
AUSTIN, TEXAS
8/24/2015 4:54:18 PM
JEFFREY D. KYLE
CLERK
COURT OF APPEALS
THIRD JUDICIAL DISTRICT OF TEXAS FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
AUSTIN, TEXAS 8/24/2015 4:54:18 PM
JEFFREY D. KYLE
Clerk
ROBIE LEE LAW § COURT OF APPEALS
Appellant § NO. 03-15-00265-CR,
§ NO. 03-15-00277-CR,
§ NO. 03-15-00288-CR
VS. §
THE STATE OF TEXAS, §
Appellee § DISTRICT COURT NO. CR 36868
STATE’S MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF
COMES NOW, the State of Texas, by and through its undersigned attorney, and
respectfully requests that the Court grant an Extension of Time for Filing the State’s
Brief in the above reference cause.
Pursuant to Rules 38.6 and 10.5(b), Texas Rules of Appellate Procedure, the
Petitioner would show in support of this Motion that:
1. The current deadline for filing Appellee’s Brief was August 21, 2015.
2. The length of time requested for an extension is an additional 3 days until
August 24, 2015;
3. The reasons for the need for an extension are that:
1) Attorney for the State believed that he had until the 23rd to
file the brief. The brief is ready and will be filed if the motion
is granted.
4. The State has not previously been granted any extensions.
Respectfully submitted,
/s/ Joseph P. Johnson
Joseph P. Johnson
Assistant County and District Attorney
Milam County, Texas
204 N. Central, Cameron, Texas 76520
Phone: (254) 697-7013
Fax: (254) 697-7016
jjohnson@milamcounty.net
State Bar No. 24092587
CERTIFICATE OF CONFERENCE
In accordance with Tex. R. App. P. 10.1(a)(5), I certify that I have conferred
with the attorney for only other party in this case, Tyler Pennington, on the merits of
this motion and that office has no objection to this motion.
/s/ Joseph P. Johnson
Joseph P. Johnson
CERTIFICATE OF SERVICE
I do hereby certify that a true and correct copy of the foregoing State's Motion
for Extension of Time to File Appellee’s Brief has been delivered to Tyler Pennington,
attorney for the Appellant, on this 24th day of August, 2015. The copy of this motion
was delivered via facsimile to Tyler Pennington, 106 S. Harris St., Ste. 125, Round
Rock, Texas 78664, at (866) 736-3690. Mr. Pennington represents Robie Lee Lawhon
in this matter.
/s/ Joseph P. Johnson
Joseph P. Johnson