Case Information

*0 FILED IN 5th COURT OF APPEALS DALLAS, TEXAS 12/15/2015 9:17:14 AM LISA MATZ Clerk *1 ACCEPTED 05-15-01313-CR FIFTH COURT OF APPEALS DALLAS, TEXAS 12/15/2015 9:17:14 AM LISA MATZ CLERK Nos. 05-15-01312-CR and 05-15-01313-CR

EX PARTE * IN THE COURT OF APPEALS

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* FOR THE FIFTH DISTRICT OF

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ROBERT ANTHONY HUNT * TEXAS AT DALLAS

MOTION TO EXTEND TIME TO FILE STATE’S BRIEF

TO THE HONORABLE COURT OF APPEALS:

The State of Texas moves the Court to grant it additional time in which to

file a brief under T EX . R. A PP . P. 38.6(d), 10.1, and 10.5(b) and, in support, shows:

I.

The Appellant’s Brief was filed on December 7, 2015, after the granting of a

motion for extension of time. The State’s Brief is due to be filed on December 22,

2015. It has become necessary for the State to request an extension of the deadline

from December 22, 2015 until January 21, 2016 (30 days).

II.

The need for an extension may be reasonably explained as follows. During

the time the undersigned was assigned the task of preparing the State’s Brief, he

was also assigned to the brief in Gregory Guajardo v. State , Cause No. 05-15-

*2 00197-CR, which is due to be filed on December 20, 2015. The undersigned has

also been assigned to write the brief in Jorge Barroquin-Tabres v. State , No. 05-

15-00794-CR, which is due to be filed on January 7, 2016.

III.

No previous extensions have been requested by the State.

IV.

This case is set for submission on February 1, 2016.

V.

W HEREFORE , the State prays this motion will be granted and that the State’s

brief be accepted for filing no later than January 21, 2016.

Respectfully submitted,

SUSAN HAWK JUSTIN T. JOHNSON

Criminal District Attorney Assistant Criminal District Attorney

Dallas County, Texas SBN 24054522

Frank Crowley Courts Building

133 N. Riverfront Blvd., LB-19

Dallas, Texas 75207

(214) 653-3604

(214) 653-3643 fax

justin.johnson@dallascounty.org

*3 CERTIFICATE OF SERVICE

I certify that a true copy of the foregoing motion has been served on Gary

Udashen, Attorney for Appellant Robert Anthony Hunt, by electronic service

through eFileTexas.gov on December 15, 2015.

Justin T. Johnson