ACCEPTED
04-14-00678-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
4/8/2015 11:33:34 AM
KEITH HOTTLE
CLERK
NO. 04-14-00678-CR
RONJEE MIDDLETON § IN THE FOURTH DISTRICT
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VS. § COURT OF APPEALS
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STATE OF TEXAS § SAN ANTONIO, TEXAS
MOTION FOR EXTENSION OF TIME
TO FILE STATE’S BRIEF
TO THE HONORABLE JUDGES OF THE FOURT COURT OF APPEALS:
NOW COMES Nicholas “Nico” LaHood, Criminal District Attorney of
Bexar County and Counsel for the State of Texas, and files this Motion asking that
the Court extend the time for filing the State’s brief.
Appellant was found guilty of aggravated assault with a deadly weapon. On
September 19, 2014, he was sentenced to 27 years in the Texas Department of
Criminal Justice, Institutional Division. Appellant filed a timely notice of appeal
on September 19, 2014. The clerk’s record was filed on November 6, 2014 and a
supplemental clerk’s record was filed on December 19, 2014. The reporter’s
record was filed on November 18, 2014 and a supplemental reporter’s record was
filed on February 5, 2015. Appellant filed his brief on March 9, 2015. The State’s
brief was due April 8, 2015. This is the State’s first motion requesting an extension
of time and the State requests a 30 day extension to May 7, 2015.
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This extension is not sought for the purpose of delaying this appeal. The
State requests an extension for the following reasons:
1) Counsel would like more time to thoroughly read the record in this case,
as well as to research and write the State’s brief.
2) Counsel has recently been transferred to the Appellate Division of the
District Attorney’s Office.
3) Due to the restructuring of the District Attorney’s Office, counsel has
been assisting the trial division with intake and presentment of cases to
the grand jury.
4) Counsel recently filed the following brief in the Fourth Court of Appeals:
a. In the Interest of D.M., Children, 04-14-00858-CV.
Therefore, counsel respectfully asks the Court to grant this extension of
time to file the State’s brief in this case.
WHEREFORE, PREMISES CONSIDERED, Counsel for the State prays
that the Court grant an extension of time to May 7, 2015 for filing the State’s brief.
Respectfully submitted,
Nicholas “Nico” LaHood
Criminal District Attorney
Bexar County, Texas
/s/ Jennifer D. Rossmeier
____________________
Jennifer D. Rossmeier
State Bar No. 24079247
Assistant Criminal District Attorney
101 W. Nueva Street
San Antonio, Texas 78205-3030
Phone: (210) 335-2734
Fax: (210) 335-2436
Email: jennifer.rossmeier@bexar.org
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CERTIFICATE OF SERVICE
I, Jennifer D. Rossmeier, Assistant District Attorney, Bexar County, Texas,
certify that a copy of the foregoing motion was delivered via electronic service to
Michael D. Robbins, on April 8, 2015.
/s/ Jennifer D. Rossmeier
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