ACCEPTED
03-13-00760-CR
3794398
THIRD COURT OF APPEALS
AUSTIN, TEXAS
1/16/2015 10:45:16 AM
JEFFREY D. KYLE
CLERK
No. 03-13-00760-CR
FILED IN
3rd COURT OF APPEALS
IN THE AUSTIN, TEXAS
1/16/2015 10:45:16 AM
JEFFREY D. KYLE
COURT OF APPEALS Clerk
THIRD DISTRICT
AUSTIN, TEXAS
JAMES BROWN,
Appellant
v.
THE STATE OF TEXAS,
Appellee.
MOTION TO EXTEND TIME FOR FILING APPELLEE'S BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
The State of Texas, by and through the District Attorney for Travis County,
respectfully moves this Court to extend the time for filing Appellee's brief. In
support of this motion, the State respectfully shows the Court as follows:
Appellee's brief in this cause is due on Friday, January 30, 2015. Appellee has
not requested any prior extension to file Appellee's brief. Appellee respectfully
requests an extension of one month.
As of January 14, 2015, I, William G. Swaim III, was appointed Special
Assistant District Attorney for this appeal. Appellee requests this extension in order
1
to have an appropriate amount of time to review the record and to respond fully to
Appellant’s brief.
PRAYER
For these reasons, the State requests the Court to grant this motion to extend
the time for filing Appellee's brief until February 27, 2015.
Respectfully submitted,
ROSEMARY LEHMBERG
DISTRICT ATTORNEY
TRAVIS COUNTY, TEXAS
/s/ William G. Swaim III
Special Assistant District Attorney
State Bar No. 00785074
P.O. Box 1748
Austin, Texas 78767
Phone (512) 854-9637
Fax No. (512) 854-9316
Bill.Swaim@traviscountytx.gov
2
CERTIFICATE OF COMPLIANCE
Pursuant to Texas Rule of Appellate Procedure 9.4(i), I hereby certify, based
on the computer program used to generate this motion, that this motion contains 337
words, excluding words contained in those parts of the brief that Rule 9.4(i) exempts
from inclusion in the word count.
/s/ William G. Swaim III
Special Assistant District Attorney
CERTIFICATE OF SERVICE
I certify that, on this the 16th day of January 2015, a copy of the foregoing
motion was sent, via U.S. mail, email, or electronically through the electronic file
manager, to the following attorney for the appellant:
Tanisa Jeffers, Esq. Brian
Bernard, Esq. Bernard &
Associates 1203 Baylor
Street Austin, TX 78703
Fax: 512.478.9827
Email: tanisaL@hotmail.com
attorneybernard@yahoo.com
/s/ William G. Swaim III
Special Assistant District Attorney
3