ACCEPTED
03-14-00541-CR
4474868
THIRD COURT OF APPEALS
AUSTIN, TEXAS
3/12/2015 1:20:37 PM
JEFFREY D. KYLE
No. 03-14-00541-CR CLERK
IN THE
FILED IN
3rd COURT OF APPEALS
COURT OF APPEALS AUSTIN, TEXAS
3/12/2015 1:20:37 PM
THIRD DISTRICT OF TEXAS JEFFREY D. KYLE
Clerk
AUSTIN, TEXAS
ROBERT TORRES § APPELLANT
VS. §
THE STATE OF TEXAS § APPELLEE
APPEAL FROM THE 299TH JUDICIAL DISTRICT COURT
TRAVIS COUNTY, TEXAS
CAUSE NO. D1-DC-12-302414
STATE'S FIRST MOTION FOR EXTENSION OF TIME
TO THE HONORABLE COURT OF APPEALS:
The State of Texas respectfully moves for an extension of the deadline for filing
the State’s brief and, in accordance with Texas Rules of Appellate Procedure 38.6 and
10.5(b), advises the Court as follows:
(a) Following his conviction for Driving While Intoxicated, the appellant filed
his notice of appeal in the above cause on July 25, 2014. Appellant’s counsel filed a
brief on February 11, 2015.
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(b) The State’s brief is currently due on March 13, 2015.
(c) This request is that the deadline for filing the State’s brief be extended by
30 days.
(d) The number of previous extensions of time granted for submission of the
State’s brief is: none.
(e) The State relies upon the following facts to reasonably explain the need
for an extension of the deadline:
1. During the period since this brief was filed, the attorney assigned to this case
has been working on other pressing appellate matters and has not had
sufficient time to prepare an adequate response to this brief.
2. This request is not made for the purpose of delay, but to ensure that the
Court has a proper State’s brief to aid in the just disposition of the above
cause.
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WHEREFORE, the State of Texas respectfully requests that the deadline for
filing the State’s brief be extended to April 13, 2015.
Respectfully submitted,
ROSEMARY LEHMBERG
District Attorney
Travis County, Texas
___________________________
Angie Creasy
Assistant District Attorney
State Bar No. 24043613
P.O. Box 1748
Austin, Texas 78767
(512) 854-9400
Fax No. 854-4810
Angie.Creasy@traviscountytx.gov
AppellateTCDA@traviscountytx.gov
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CERTIFICATE OF COMPLIANCE AND SERVICE
I hereby certify that this motion contains 228 words, based upon the
computer program used to generate this motion and excluding words contained in
those parts of the motion that Texas Rule of Appellate Procedure 9.4(i) exempts
from inclusion in the word count, and that this motion is printed in a conventional,
14-point typeface.
I further certify that, on the 12th day of March, 2015, a true and correct copy
of this motion was served, by U.S. mail, electronic mail, facsimile, or electronically
through the electronic filing manager, to the Appellant’s attorney, Jamie Spencer,
Attorney at Law, 812 San Antonio St., Suite 403, Austin, Texas 78701.
___________________________
Angie Creasy
Assistant District Attorney
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