PD-0046-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 1/20/2015 5:07:51 PM
Accepted 1/22/2015 3:44:31 PM
ABEL ACOSTA
CLERK
CAUSE No.
PD-0046-15
IN THE CRIMINAL COURT OF APPEALS
AUSTIN, TEXAS
DONALD WESTON KING,
Petitioner/Appellant
VS.
January 22, 2015
STATE OF TEXAS,
RespondeiWAppellee
FIRST MOTION FOR EXTENSION OF TIME IN WHICH
TO FILE STATE’S REPLY TO
PETITION FOR DISCRETIONARY REVIEW
To THE HONORABLE JUSTICES OF THE CRIMINAL COURT OF APPEALS:
The State files this First Motion for Extension of Time in Which
to File State’s Reply to Petition for Discretionary Review, and in
support states:
i. The State’s current deadline for filing its brief is January
30, 2015.
2. This is the State’s first Motion For Extension of Time in
which to file its reply.
3. The State respectfully requests an extension of
approximately seven days, until February 6, 2015 in which
to file its reply.
4. Good cause exists for the State’s request for extension of
time in which to file its reply. Our office has experienced
drastic changes in the flow of case assignments due to new
administration. This has significantly delayed the
completion of this reply.
5. This extension is not being sought to cause undue delay,
but to seek justice.
6. For the foregoing reasons, the State respectfully requests
that the Court grant an approximate seven-day extension
for filing State’s Reply to Petition for Discretionary Review
until February 6, 2015.
Respectfully submitted,
nifer Stlbaum
sistan C iminal District Attorney
ays Co ty, Texas
ays County Government center
712 South Stagecoach Trail, Ste. 2057
San Marcos, Texas 78666
jennifer.stalbaum@co.hays.tx.us
(512) 393-7600
(512) 393-2246 fax
State Bar No. 24079383
COUNSEL FOR APPELLEE
The foregoing Appellant Motion for Extension of Time in Which
to File State’s Reply to Petition for Discretionary Review was
subscribed and sworn to before me by Jennifer Stalbaum on this the
c
20th day of January 2015.
Je m er Stalbaum
F*IONOA WEDERSTEIN
r-n MY COMMISSION EXPIRES
Sepnter9, 2018
Notary Public in and for the State of Texas
CERTIFICATE OF CONFERENCE
I certify that I emailed Appellant’s attorney Kevin Fine at
kfine@kevinfinelaw.com to ask if he opposed the extension, on
January 20, 2015 at :i p.m. Mr. Fine responded that he does not
object.
t\ /‘\
Jennifer Stali
CERTIFICATE OF SERVICE
I certify that on January 20, 2015, I served the above motion by
email to kfine@kevinfinelaw.com, in accordance with the Texas Rules
of Appellate Procedure.
)çjnifer ttabaum