ACCEPTED
04-14-00246-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
5/20/2015 10:07:51 AM
KEITH HOTTLE
CLERK
No. 04-14-00246-CR
IN THE COURT OF APPEALS
FILED IN
FOURTH COURT OF APPEALS DISTRICT OF TEXAS 4th COURT OF APPEALS
SAN ANTONIO, TEXAS SAN ANTONIO, TEXAS
5/20/2015 10:07:51 AM
____________________________________________________________
KEITH E. HOTTLE
DESTYN DAVID FREDERICK, Clerk
Appellant
v.
THE STATE OF TEXAS,
Appellee
______________________________________________________________________________
On Appeal from the 81st District Court
Frio County, Texas
Cause Number 11-09-00041-CRL
______________________________________________________________________________
STATE’S FIRST MOTION FOR EXTENSION
OF TIME TO FILE BRIEF
______________________________________________________________________________
Rene M. Pena
District Attorney
81st JUDICIAL DISTRICT OF TEXAS
Marc Ledet
Assistant District Attorney
81st / 218th JUDICIAL DISTRICT OF TEXAS
1327 3RD STREET
Floresville, Texas 78026
Tele: (830) 393-2200
Fax: (830) 393-2205
State Bar No. 24002459
Attorneys for the State of Texas
STATE’S FIRST MOTION FOR EXTENSION
OF TIME TO FILE BRIEF
The State of Texas, under the authority of Rules 10.5(b) and 38.6(d), Texas Rules
of Appellate Procedure asks the Court to extend time to file the State’s Brief from May
20, 2015, to and including June 19, 2015, a period of thirty (30) days.
1. Appellant was found guilty in cause number 11-09-00041-CRl for Murder.
2. The State’s Brief is presently due on May 20, 2015.
3. The State of Texas respectfully requests an additional thirty (30) days to file its
brief, that is, an extension of time until June 19, 2015.
4. No previous extension has been requested by the State.
5. The State of Texas requests this extension based on the following reasons:
A. The 81st Judicial District Attorney’s Office covers five (5) counties and
over two hundred miles. Our office does not have an appellate section.
All appellate work is done at times when prosecutors are not in court, not
preparing for trial, or not preparing for grand jury.
B. The State is still in the process of reviewing the reporter’s record and
clerk’s record, as well as Appellant’s brief to ensure that the State’s Brief
is fully conversant on all legal and factual points before the court.
For these reasons, the State asks the Court to grant an extension of thirty (30) days
to June 19, 2015, within which the State may file its brief in this cause.
Respectfully submitted,
Rene M. Pena
District Attorney
81st JUDICIAL DISTRICT OF TEXAS
TEXAS BAR NUMBER 00792752
/S MARC LEDET
Marc Ledet
Assistant District Attorney
81st JUDICIAL DISTRICT OF TEXAS
1327 3RD STREET
Floresville, Texas 78026
Telephone (830) 393-2200
Telecopier (830) 393-2205
TEXAS BAR NUMBER 24002459
Attorneys for the State of Texas
Certificate of Service
I hereby certify that the above and foregoing was sent to Richard Langlois, 217
Arden Grove, San Antonio, TX 78215 on the 20th day of May, 2015 in accordance with
the Texas Rules of Procedure.
/s Marc Ledet