ACCEPTED
03-15-00153-CR
7902546
THIRD COURT OF APPEALS
AUSTIN, TEXAS
11/19/2015 11:16:59 AM
JEFFREY D. KYLE
CLERK
No. 03-15-00153-CR FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
11/19/2015 11:16:59 AM
IN THE COURT OF APPEALS FOR THE THIRD
JEFFREY D. KYLE
DISTRICT OF TEXAS Clerk
THE STATE OF TEXAS, Appellant
v.
FRANCES ANITA ROBINSON, Appellee
On Appeal from the 207th Judicial District Court of Co mal County, Texas
Cause No. CR2013-267
Honorable Bruce Boyer, District Judge Presiding
MOTION TO EXTEND TIME TO FILE APELLEE'S BRIEF
Sullivan & Associates, PLLC
By
Charles Sullivan
Texas Bar No. 24049421
308 Campbell Drive
Canyon Lake, TX 78133
(830) 899-3259 Phone
(210) 579-6448 Fax
csullivan@lawcullivan.com
Attorney for Appellee Robinson
MOTION TO EXTEND TIME TO FILE APPELLEE'S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes Francis Anita Robinson, Appellee in the above styled and numbered
cause, and moves this Court to grant an extension of time to file appellant's brief,
pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good cause
shows the following:
1. This case is on appeal from the 207th Judicial District of Comal County,
Texas.
2. The case below was styled the STA1E OF TEXAS vs. FRANCES ANITA
ROBINSON, and numbered CR2013-267.
3. Appellant State is appealing Motion to Supress Evidence granted by the
trial court on February 18, 2015.
4. The appellate filed their brief on October 16,2015.
5. Appellee requests an extension of time of 30 days from the present date, i.e.
November 19, 2015.
6. No extensions to file the brief have been previously received in this cause.
7. Defendant is currently free on bond.
WHEREFORE, PREMISES CONSIDERED, Appellee prays that this Court
grant this Motion To Extend Time to File Appellee's Brief, and for such other and further
relief as the Court may deem appropriate.
No. 03-15-00153-CR, State v Robinson, Motion to Extend Time to File Appellee's Brief
C rles W. Sullivan
Texas Bar No. 24049421
Sullivan & Associates, PLLC
308 Campbell Drive
Canyon Lake, TX 78133
(830) 899-3259 Phone
(21 0) 579-6448 Fax
STATE OF TEXAS §
§
COUNTY OF COMAL §
AFFIDAVIT
BEFORE ME, the undersigned authority, on this day personally appeared
Charles Sullivan, who after being duly sworn stated:
"I am the attorney for the appellant in the above numbered and entitled
cause. I have read the foregoing Motion To Extend Time to File Appellant's
Brief and swear that all of the allegations of fact contained therein are true
and correct."
No. 03-15-00153-CR, State v Robinson, Motion to Extend Time to File Appellee's Brief
SUBSCRIBED AND SWORN TO BEFORE ME on November 19, 2015, to
certify which witness my hand and seal of office.
A--$_ .i
lJ ·.- >J /
{ ;! 1: ~: ~~>,_ ' -r't.-.'}::r''\-·"1 ...··:-:. _. .~,----~
·- _/'1'-{:dtary'Puhlic. State ot> t'xas
-....~·
Certificate of Service
I, Charles Sullivan, attorney for Frances Anita Robinson, Appellee, hereby certify
that a true and correct copy of this Motion has been delivered to Appellant via State's
attorney of record in this matter:
Jennifer Tharp, Criminal District Attorney
Daniel Palmitier, Assistant District Attorney
150 N. Seguin Avenue, Suite #307
New Braunfels, Texas 78130
(830) 221-1300
Fax (830) 608-2008
E-mail: preslj @co. comal. tx. us
Attorneys for State
By electronically sending it through efile.txcourts.gov service, this 19th day of
November, 2015.
c
No. 03-15-00153-CR, State v Robinson, Motion to Extend Time to File Appellee's Brief