ACCEPTED
07-15-00115-CR
SEVENTH COURT OF APPEALS
AMARILLO, TEXAS
8/12/2015 12:58:49 PM
Vivian Long, Clerk
NO. 07-15-00115-CR
ISFRAEL GONZALEZ § IN THE COURT OF APPEALS
FILED IN
7th COURT OF APPEALS
AMARILLO, TEXAS
VS. § FOR THE SEVENTH DISTRICT
8/12/2015 12:58:49 PM
VIVIAN LONG
THE STATE OF TEXAS § CLERK
OF TEXAS AT AMARILLO
STATE’S MOTION TO EXTEND THE TIME
FOR FILING THE STATE’S BRIEF
TO THE HONORABLE JUDGES OF SAID COURT:
The State of Texas respectfully requests that the time for filing its brief in this
cause be extended. In support of this motion the State would show the Court the
following:
Appellant pleaded guilty and was placed on probation for engaging in
organized criminal activity; this appeal is from his probation revocation, after which
he was assessed a sentence of confinement for eight years in TDCJ. Appellant is
currently incarcerated. Appellant filed his brief on July 7, 2015, and the State’s brief
was due August 10, 2015. The State requests an extension of time to file its brief until
September 10, 2015.
Counsel has good cause for the delay in filing this brief. The Cooke County
D.A.’s Office had requested the undersigned to prepare and file the brief and
represent the State of Texas in this appeal as a special prosecutor, because that office
does not have an appellate attorney. Undersigned counsel is unable to timely
complete the brief due to a final illness and death in counsel’s household, and the
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District Attorney has therefore agreed to reassign the brief to another local attorney
as special prosecutor. No previous extension has been requested by the State in this
matter.
WHEREFORE, PREMISES CONSIDERED, the State respectfully requests
that the time for filing the State’s brief be extended until September 10, 2015.
Respectfully submitted,
by: ____/s/ Sue Korioth___________
JANICE WARDER Sue Korioth, Texas Bar #11681975
Cooke County District Attorney Special Prosecutor
Cooke County Courthouse Cooke County D. A.’s Office
Gainesville, Texas 76240-4760 P.O. Box 600103
(940) 668-5466 Telephone Dallas, Texas 75360-0103
(940) 668-5499 Facsimile (214) 384-3864
suekorioth@aol.com
CERTIFICATE OF SERVICE
I hereby certify that a true copy of the foregoing has been served on Christopher
Graham, Attorney for Appellant, by email or by e-service if available to his address
at clgraham@lgi-law.com .
____/s/ Sue Korioth_________
SUE KORIOTH
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