ACCEPTED
03-14-00676-CR
6685580
THIRD COURT OF APPEALS
AUSTIN, TEXAS
8/27/2015 3:24:03 PM
JEFFREY D. KYLE
CLERK
NO. 03-14-00676-CR
ANGELITA RODRIGUEZ PACHECO, § IN THE COURT OF APPEALS
FILED IN
Appellant § 3rd COURT OF APPEALS
§ AUSTIN, TEXAS
VS. § THIRD DISTRICT
8/27/2015 3:24:03 PM
§ JEFFREY D. KYLE
§ Clerk
THE STATE OF TEXAS, § AUSTIN, TEXAS
Appellee §
MOTION FOR EXTENSION OF TIME
TO FILE APPELLEE’S BRIEF
This motion is presented by the State of Texas, by and through the
undersigned Assistant District Attorney, and in support would show:
I.
The Appellant’s brief was filed on July 28, 2015. The brief for the State of
Texas, Appellee, is due on August 27, 2015.
II.
The undersigned serves as an Assistant District Attorney in the 33 rd and 424th
District Attorney’s office in Burnet, Texas. In the time since the Appellant
submitted her brief, the undersigned has been required to take on additional day-to-
day responsibilities as a result of the departure of another Assistant District Attorney
from the 33rd and 424th District Attorney’s office, leaving only the undersigned and
one other Assistant District Attorney to manage the general felony criminal docket
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for Burnet County. As a result, in the last month the undersigned has been required
to prepare three cases for trial (on August 3rd, August 11th, and August 17th) and
managed nine criminal docket settings and one Grand Jury setting. These
circumstances have not afforded the time to perform the research necessary to
adequately address the points raised by the Appellant in his brief.
III.
In this case Appellant raises four issues which will require extensive research
and a thorough familiarity with the trial record to adequately address. The
undersigned will need an additional 60 days to prepare and file the Appellee’s Brief
in this case. This is the first motion for extension of time that the State of Texas has
sought in this case.
PRAYER
The State of Texas, in consideration of the facts and circumstances set forth
herein above, prays the Court grant this motion and extend the due date for the
Appellee’s Brief to October 26, 2015.
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Respectfully submitted,
OFFICE OF DISTRICT ATTORNEY
33RD and 424th JUDICIAL DISTRICTS
Wiley B. McAfee, District Attorney
P. O. Box 725
Llano, Texas 78643
Telephone Telecopier
(325) 247-5755 (325) 247-5274
/s/ R. Blake Ewing
By: ________________________________
R. Blake Ewing
Assistant District Attorney
State Bar No. 24076376
ATTORNEY FOR APPELLEE
CERTIFICATE OF SERVICE
This is to certify that a true copy of the above and foregoing instrument,
together with this proof of service hereof, has been forwarded on the 27th day of
August 2015, to Mr. Gary Prust, Attorney for Appellant, by facsimile and/or by
email at gary@prustlaw.com
/s/ R. Blake Ewing
_____________________________
R. Blake Ewing
Assistant District Attorney
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