ACCEPTED
01-15-00367-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
12/28/2015 3:48:44 PM
CHRISTOPHER PRINE
CLERK
N0.01-15-00367-CR
COURT OF APPEALS FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
FOR THE
12/28/2015 3:48:44 PM
FIRST SUPREME JUDICIAL DISTRICT CHRISTOPHER A. PRINE
Clerk
REYNALDO ZAMORA,
Appellant
VS.
THE STATE OF TEXAS,
Appellee
APPEAL FROM
THE 22ND JUDICIAL DISTRICT COURT
HAYS COUNTY, TEXAS
TRIAL COURT CAUSE NO. 87-0140
FIRST MOTION FOR EXTENSION OF
TIME IN WinCH TO FILE STATE'S BRIEF
Brian Erskine
Criminal District Attorney
712 South Stagecoach Trail, Suite 2057
San Marcos, Texas 78666
State Bar No. 24074182
Attorney for the State of Texas
brian.erskine@co.hays.tx.us
Page 1
TO THE HONORABLE JUSTICE OFTHE FIRST COURT OF APPEALS:
The State files this First Motion for Extension of Time in Which to File State's
Brief, and in support states:
L The State's current deadline for filing its brief is January 6,2016.
2. This is the State's first Motion for Extension of Time in which to file its
brief
3. The State respectfully requests an extension of approximately thirty days,
until February 5,2016 in which to file its brief
4. This extension is not being sought to cause undue delay, but to seek justice.
Respectfully submitted,
Brian Erskine
Asst. Criminal District Attorney
P.O. Box 12548
Austin, Texas 78711-2548
State BarNo.24074182
Attorney for the State of Texas
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CERTIFICATE OF SERVICE
I certify that a true copy ofthe foregoing brief has been email-delivered to:
Alexander L. Calhoun via email: alcalhoun@earthlink.net on this the 28th day of
December, 2015.
fBrian Erskine
Asst. Criminal District Attorney
Page 3