ACCEPTED
12-15-00055-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
5/8/2015 3:45:45 PM
CATHY LUSK
CLERK
Cause No. 12-15-00055-cR
JORGE ZEPEDA $ IN THE COI]RT OF APPEALS
$ FILED IN
V. $ 12TH DISTRICT12th COURT OF APPEALS
COURT
TYLER, TEXAS
$
STATE OF TEXAS TYLER, TEXAS5/8/2015 3:45:45 PM
CATHY S. LUSK
Clerk
TO THE HONORABLE JUDGES OF SAID COURT:
COMES NOW, Appellant, through JEFF SANDERS, Defense Attorney, in the above
show the Court as
styled and numbered cause and files this Motion and in support thereof would
follows:
1. The Appellant's Brief is due on May 11,2015. Appellant's attorney needs 30
additional days to file the brief. This is the first request for an extension.
2. I have been involved in trial preparation for State v. Kaylee Harrod, cause numbers
CR14-28 1 and CRl 4- 323 , in Rusk County District Court set for Ap/rl 27 , 2015
(delivery of a controlled substance and endangering a child). Additionally' I've been
working on trial preparation for State v. John Mumphrey, cause number 43486-A, in
Gregg County District Court that had been set for trial April 20, 2015 (felony DWD.
Furthermore, I have been involved in case preparation on State v. Jacob Roper, cause
number t14-0320-15 & 114-0321-15 &,114-0322-l5,in smith county (two counts
ofaggravated robbery and burglary ofa building)'
3. This motion is not made for purposes of delay, but so that justice may be done.
granted.
WHEREFORE, PREMISES CONSIDERED, the Appellant requests that this motion for be
Re specJf-ully S ubmiued
State Bar Number 24033153
ELLIS ANd SANDERS PLLC
120 S. Broadway Suite 112
Tyler, Texas 75702
Pirone (903)595-1 13 1 Fax (903)595-5532
CEhRTIFICATE OF SERVICE
attorney
This is to certiff that a true and correct copy of the foregoing Motion was served upon the
for the State on 8TH of May,2A15.
VERIFICATION
STATE OF TEXAS $
$ KNOW ALL MEN BY THESE PRESENTS
COUNTY OF SMITH $
.,My name is JEFF SANDERS and I am the attorney for the Appellant in this case. I have
knowledge of the facts stated in the foregoing Motion and they are true and correct."
Signed on 0rta.1 8 ,2a15.
SWORN AND SUBSCRIBED TO BEFORE ME, the undersigned Notary Public on
Glnot Atffi HoYtril
fy Commtrrhn Erghrg
April 26, 2016
Notary Public in and for the State of