Case Information

*0 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 1/20/2015 9:14:00 AM DEBBIE AUTREY Clerk *1 ACCEPTED 06-14-00206-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 1/19/2015 6:24:14 PM DEBBIE AUTREY CLERK CAUSE NO. 06-14-00206-CR

CINQUE ROSS § IN THE COURT OF APPEALS

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VS. §IN AND FOR THE SIXTH DISTRICT

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THE STATE OF TEXAS § OF THE STATE OF TEXAS

STATE'S FIRST MOTION TO EXTEND TIME

FOR FILING STATE’S BRIEF

TO THE HONORABLE JUDGE OF SAID COURT:

THE STATE OF TEXAS, by and through the undersigned Assistant District

Attorney, respectfully moves the Court to extend the time for filing of the

Appellee’s Brief in accordance with Rule 10.5 of the Texas Rules of Appellate

Procedure. In support of its motion, the State respectfully offers the following: The Appellee’s brief is due Tuesday, January 20, 2015, and I have not

completed it due to other matters with more pressing deadlines. The State seeks an additional 30 days, until February 19, 2015. The undersigned

will, nonetheless, attempt to complete and file the State’s brief prior to the

extended deadline. The undersigned attorney is responsible for all post-conviction prosecution for

the Gregg County Criminal District Attorney’s Office, including direct appeals

and applications for habeas corpus.

In the past 30 days the undersigned attorney has worked on the following:

A. Appellate Briefs: Appellate Briefs: December 19, 2014, Lawson v. State, 06-14-00022-CR Ray v. State, 06-14-00106-CR.

3. January 16, 2015 Duckett v. State, 06-14-00106-CR

4. January 19, 2015 Lewis v. State, 06-14-00111-CR

B. Responses to Writ Applications: January 2, 2015, Ex parte Dennis Freeman 42,132 B-H-1 Ex pate Robert Wyatt 40,788-A-H-1 January 13, 2015 Ex parte Christopher Howard 37,568A-

H-2.

C. Numerous traffic court appeals and bond forfeiture cases. I took two days for Christmas and one day for New Year’s Day.

In the next 30 days the undersigned attorney must respond to the following

in addition to this brief:

A. Appellate Briefs due after one extension:

1. Harris v. State, 06-14-00162-CR requested extension to

February 4, not yet granted.

B. Appellate Briefs due without extensions:

1. Hammack v. State, 06-14-00175-CR,January 20, 2015.

2. Schelling v. State, 06-14-00175-CR, January 29, 2015.

3. Kelly v. State, 06-12-00141-CR, February 2, 2015 (I

must respond to Appellant’s pro se brief responding to an

Anders brief).

4. Palmer v. State, (I must review, and if necessary,

respond to Appellant’s petition for discretionary review) Appellant relies on the following facts as good cause for the requested

extension:

a. During the past 30 days, the undersigned has submitted four appellate briefs,

and three habeas responses, as shown above. In addition, I have processed

numerous traffic court appeals and bond forfeiture cases.

b. No previous extensions have been requested by the State in this case.

c. This extension is not requested for purposes of delay, but so that justice may

be done.

d. I still have not completely cleared the case backlog that has built up over the

past few months.

Respectfully submitted, /s/ Zan Colson Brown Zan Colson Brown Texas Bar No. 03205900 Assistant District Attorney 101 East Methvin St., Suite 333 Longview, TX 75601 Telephone: (903) 236–8440 Facsimile: (903) 236–3701 E-mail: zan.brown@co.gregg.tx.us CERTIFICATE OF SERVICE

I certify that a true and correct copy of the above and foregoing has been

forwarded to all counsel of record by electronic transmission to:

Mr. Lew Dunn

P.O. Box. 2226

Longview, Texas 75606

Dunn@texramp.net

This 19th day of January, 2015.

/s/ ZanColsonBrown Zan Colson Brown Assistant District Attorney