ACCEPTED
05-15-01313-CR
FIFTH COURT OF APPEALS
DALLAS, TEXAS
12/15/2015 9:17:14 AM
LISA MATZ
CLERK
Nos. 05-15-01312-CR and 05-15-01313-CR
EX PARTE * IN THE COURT OF APPEALS
FILED IN
5th COURT OF APPEALS
* DALLAS, TEXAS
* 12/15/2015 9:17:14 AM
* FOR THE FIFTH DISTRICT OF
LISA MATZ
* Clerk
*
ROBERT ANTHONY HUNT * TEXAS AT DALLAS
MOTION TO EXTEND TIME TO FILE STATE’S BRIEF
TO THE HONORABLE COURT OF APPEALS:
The State of Texas moves the Court to grant it additional time in which to
file a brief under TEX. R. APP. P. 38.6(d), 10.1, and 10.5(b) and, in support, shows:
I.
The Appellant’s Brief was filed on December 7, 2015, after the granting of a
motion for extension of time. The State’s Brief is due to be filed on December 22,
2015. It has become necessary for the State to request an extension of the deadline
from December 22, 2015 until January 21, 2016 (30 days).
II.
The need for an extension may be reasonably explained as follows. During
the time the undersigned was assigned the task of preparing the State’s Brief, he
was also assigned to the brief in Gregory Guajardo v. State, Cause No. 05-15-
MOTION TO EXTEND TIME TO FILE STATE’S BRIEF Page 1 of 3
00197-CR, which is due to be filed on December 20, 2015. The undersigned has
also been assigned to write the brief in Jorge Barroquin-Tabres v. State, No. 05-
15-00794-CR, which is due to be filed on January 7, 2016.
III.
No previous extensions have been requested by the State.
IV.
This case is set for submission on February 1, 2016.
V.
WHEREFORE, the State prays this motion will be granted and that the State’s
brief be accepted for filing no later than January 21, 2016.
Respectfully submitted,
/s/ Justin T. Johnson
SUSAN HAWK JUSTIN T. JOHNSON
Criminal District Attorney Assistant Criminal District Attorney
Dallas County, Texas SBN 24054522
Frank Crowley Courts Building
133 N. Riverfront Blvd., LB-19
Dallas, Texas 75207
(214) 653-3604
(214) 653-3643 fax
justin.johnson@dallascounty.org
MOTION TO EXTEND TIME TO FILE STATE’S BRIEF Page 2 of 3
CERTIFICATE OF SERVICE
I certify that a true copy of the foregoing motion has been served on Gary
Udashen, Attorney for Appellant Robert Anthony Hunt, by electronic service
through eFileTexas.gov on December 15, 2015.
/s/ Justin T. Johnson
Justin T. Johnson
MOTION TO EXTEND TIME TO FILE STATE’S BRIEF Page 3 of 3