ACCEPTED
03-14-00559-CR
5402647
THIRD COURT OF APPEALS
AUSTIN, TEXAS
5/22/2015 3:23:09 PM
JEFFREY D. KYLE
CLERK
No. 03-14-00559-CR
Court of Appeals FILED IN
3rd COURT OF APPEALS
for the AUSTIN, TEXAS
Third Supreme Judicial District of Texas 5/22/2015 3:23:09 PM
JEFFREY D. KYLE
At Austin Clerk
Zane Lynn Barton,
Appellant
VS.
The State of Texas,
Appellee
Appeal From
274th District Court of
Hays County, Texas
Trial Court Cause Number CR-13-0614
First Motion For Extension
of Time in Which to File State's Brief
Laura Garcia
Asst. Criminal District Attorney
Hays County Government Center
712 South Stagecoach Trail, Ste. 2057
San Marcos, Texas, 78666
512-393-7600
laura. garcia@co.hays .tx.us
State Bar No. 24074249
Attorney for the State of Texas
TO THE HONORABLE JUSTICES OF THE THIRD COURT OF
APPEALS:
The State files this First Motion for Extension of Time in Which to File
State's Brief, and in support states:
1. The State's current deadline for filing its brief is May 22, 2015.
2. This is the State's first Motion for Extension of Time in which to file
her brief
3. The State respectfully requests an extension of approximately forty-
five days, until July 6, 2015 in which to file her brief
4. Good cause exists for the State's request for extension of time in which
to file its brief The undersigned attorney is working on possible agreed
supplement of the record.
5. These circumstances have significantly delayed the completion of this
brief
6. This extension is not being sought to cause undue delay, but to seek
justice.
7. For the foregoing reasons, the State respectfiilly requests that the Court
grant an approximate thirty day extension for filing Appellee's Brief,
until July 6, 2015.
Respectfully submitted.
ira Garch
Asst. Criminal District Attorney
Hays County Government Center
712 South Stagecoach Trail, Ste. 2057
San Marcos, Texas, 78666
512-393-7600
laura.garcia@co.hays.tx.us
State Bar No. 24074249
Attorney for the State, of Texas
The foregoing Appellant Motion for Extension of Time in Which to
File Appellant's Brief was subscribed and sworn to before me by Laura
Garcia on this the 22nd of May, 2015.
Laura jGarcia
RHONDA WIEDERSTEIN
>1 MY COMMISSION EXPIRES
Septembers, 2018
Notary Public in and for the State of Texas
CERTIFICATE OF SERVICE
I certify that on May 22, 2015, I served the above motion by email to
Amanda Erwin at amanda@theerwinlawfirm.com, in accordance with the
Texas Rules of Appellate Procedure.
Zane Lynn Barton v. State
Combined Opinion