Case Information

*0 FILED IN 12th COURT OF APPEALS TYLER, TEXAS 5/8/2015 3:45:45 PM CATHY S. LUSK Clerk *1 ACCEPTED 12-15-00055-CR TWELFTH COURT OF APPEALS TYLER, TEXAS 5/8/2015 3:45:45 PM CATHY LUSK CLERK

Cause No. 12-15-00055-cR IN THE COI]RT OF APPEALS

JORGE ZEPEDA $ $ 12TH DISTRICT COURT

V. $ $ TYLER, TEXAS

STATE OF TEXAS

TO THE HONORABLE JUDGES OF SAID COURT:

COMES NOW, Appellant, through JEFF SANDERS, Defense Attorney, in the above

styled and numbered cause and files this Motion and in support thereof would show the Court as

follows:

1. The Appellant's Brief is due on May 11,2015. Appellant's attorney needs 30

additional days to file the brief. This is the first request for an extension.

2. I have been involved in trial preparation for State v. Kaylee Harrod, cause numbers

CR14-28 1 and CRl 4- 323 , in Rusk County District Court set for Ap/rl 27 , 2015

(delivery of a controlled substance and endangering a child). Additionally' I've been

working on trial preparation for State v. John Mumphrey, cause number 43486-A, in

Gregg County District Court that had been set for trial April 20, 2015 (felony DWD.

Furthermore, I have been involved in case preparation on State v. Jacob Roper, cause

number t14-0320-15 & 114-0321-15 &,114-0322-l5,in smith county (two counts

ofaggravated robbery and burglary ofa building)'

3. This motion is not made for purposes of delay, but so that justice may be done.

WHEREFORE, PREMISES CONSIDERED, the Appellant requests that this motion for be granted.

Re specJf-ully S ubmiued

State Bar Number 24033153

ELLIS ANd SANDERS PLLC

120 S. Broadway Suite 112

Tyler, Texas 75702

Pirone (903)595-1 13 1 Fax (903)595-5532

CEhRTIFICATE OF SERVICE a true and correct copy of the foregoing Motion was served upon the attorney

This is to certiff that

for the State on 8TH of May,2A15.

VERIFICATION

STATE OF TEXAS $ $ KNOW ALL MEN BY THESE PRESENTS

COUNTY OF SMITH $

.,My name is JEFF SANDERS and I am the attorney for the Appellant in this case. I have

knowledge of the facts stated in the foregoing Motion and they are true and correct."

Signed on 0rta.1 8 ,2a15.

SWORN AND SUBSCRIBED TO BEFORE ME, the undersigned Notary Public on Glnot Atffi HoYtril

fy Commtrrhn Erghrg April 26, 2016

Notary Public in and for the State of