ACCEPTED
03-14-00802-CR
8185149
THIRD COURT OF APPEALS
AUSTIN, TEXAS
12/10/2015 3:34:44 PM
JEFFREY D. KYLE
CLERK
No. 03-14-00802-CR
PEDRO ELIZONDO MARTINEZ, JR. § IN THE COURT OF APPEALS
FILED IN
3rd COURT OF APPEALS
§ AUSTIN, TEXAS
v. § 12/10/2015DISTRICT
THIRD 3:34:44 PM
§ JEFFREY D. KYLE
Clerk
STATE OF TEXAS § AUSTIN, TEXAS
MOTION FOR EXTENSION OF TIME TO FILE BRIEF
NOW COMES THE STATE OF TEXAS, Appellee, by and through her
Assistant District Attorney, and moves the Court, pursuant to Texas Rule of Appellate
Procedure 38.6(d), to extend the deadline for filing the State’s brief. In support of its
motion, the State would show the Court the following:
1. The State’s Brief in this case is due on December 8, 2015.
2. Two previous extensions of time have been requested by the State and granted by
this Court.
3. Appellant’s brief was filed in this Court on July 10, 2015.
4. Due to the complexity and serious nature of the issues raised by Appellant,
preparation for writing the State’s brief took considerably more time than
anticipated.
5. Therefore, the time required to write the response brief extended several days
longer than the State anticipated.
6. For the foregoing reasons, The State respectfully requests that the deadline for
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filing its brief in the above stated cause be extended for an additional two (2) days
from the current due date of December 8, 2015, to the date of filing of the brief on
December 10, 2015.
WHEREFORE, PREMISES CONSIDERED, the State of Texas respectfully
requests that this Court grant its motion for an extension of time and extend the State’s
deadline to file its brief to December 10, 2015.
Respectfully submitted,
Jana Duty
District Attorney
Williamson County, Texas
/s/ Daniel Sakaida
Daniel Sakaida
State Bar No: 24084601
Assistant District Attorney
405 Martin Luther King, Box 1
Georgetown, Texas 78626
(512) 943-1234
(512) 943-1255 (fax)
daniel.sakaida@wilco.org
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Certificate of Service
I hereby certify that on December 10, 2015, I electronically filed the foregoing
document with the clerk of the court for the Texas Court of Criminal Appeals, using
the efile.txcourts.gov system. Via that system, a “Notice of Electronic Filing” was sent
to Appellee’s appellate attorney of record, Ellic Sahualla, 600 W. 13th St., Austin,
Texas 78701 at ellic@Sahuallalaw.com.
/s/ Daniel Sakaida_______________
DANIEL SAKAIDA
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