Case Information
*0 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 5/21/2015 10:44:50 AM DEBBIE AUTREY Clerk *1 ACCEPTED 06-14-00225-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 5/21/2015 10:44:50 AM DEBBIE AUTREY CLERK NOS. 06-14-00225-CR, 06-14-00226-CR, AND 06-14-00227-CR
[TRIAL COURT NOS. F12-61870-X, F13-34344-X, and F13-40734-X]
]
THE STATE OF TEXAS § IN THE COURT OF APPEALS
VS. § FOR THE SIXTH DISTRICT
ELIZABETH MENDOZA § OF TEXAS AT DALLAS
STATE’S MOTION TO EXTEND THE TIME FOR
FILING THE STATE’S BRIEF
TO THE HONORABLE COURT OF APPEALS:
COMES NOW the State of Texas, through the Criminal District Attorney of
Dallas County, and files this Motion to Extend the Time for Filing State’s Brief nine
(9) days until May 22, 2015, and would show the following:
I.
Appellant pleaded guilty under three separate indictments to the unrelated
offenses of aggravated assault (F12-61870-X), attempted possession of a controlled
substance (F13-34344-X), and unauthorized use of a motor vehicle (F13-40734). In
each case, the trial court placed appellant on deferred adjudication community
supervision. The State subsequently filed motions to adjudicate guilt in each of
appellant’s cases and appellant entered non-negotiated guilty pleas to the allegations
alleged in the State’s motions. On November 13, 2014, the trial court presided over a
consolidated hearing on all three cases. The trial court adjudicated guilt in all three
cases and assessed appellant’s punishments as six years imprisonment in F12-61870-X,
one year in the county jail in cause number F13-34344-X, and ten months in a state jail
facility in cause number F13-40734-X.
II.
This case is not yet set for submission. No prior extensions have been requested
by the State in this case.
III.
On May 20, 2015, I filed a seventy-four page brief in the Fifth District Court of
appeals in Paz v. State , 05-14-01127-CR. I spent the preceding four weeks preparing
the States brief, which include reading the eight volume reporter’s record and writing
and editing a problematic statement of facts. I originally intended to file said brief
several weeks earlier, and then address the other appellate briefs, including the brief in
the instant case, in a more timely fashion. Unfortunately, I was unable to finish the Paz
brief for filing until yesterday afternoon (May 20, 2015). For this reason, the State
respectfully requests that the time for filing the State’s brief be extended nine (9) days
until May 22, 2015.
IV.
WHEREFORE, PREMISES CONSIDERED, the State respectfully requests that
the time for filing the State’s brief be extended nine (9) days until May 22, 2015.
Respectfully submitted, LARISSA T. ROEDER ASSISTANT DISTRICT ATTORNEY STATE BAR NO. 24010357 FRANK CROWLEY COURTS BLDG, LB 19 DALLAS, TEXAS 75207-4399 (214) 653-3636 *4 CERTIFICATE OF SERVICE AND WORD-COUNT COMPLIANCE
I hereby certify that a true copy of this motion has been served on, Bruce Anton,
attorney for appellant, 2311 Cedar Springs, Suite 250, Dallas, Texas 75201, via
electronic mail at ba@sualaw.com on May 21, 2015. I further certify that this
document contains 466 words, inclusive of all contents.
LARISSA T. ROEDER