Case Information

*0 FILED IN 12th COURT OF APPEALS TYLER, TEXAS 9/23/2015 10:46:49 PM PAM ESTES Clerk *1 ACCEPTED 12-15-00003-CR TWELFTH COURT OF APPEALS TYLER, TEXAS 9/23/2015 10:46:49 PM Pam Estes CLERK Cause No. 12-15-00003-CR

In the Court of Appeals for the

Twelfth Judicial District at Tyler, Texas Dequisha Jackson,

Appellant

v.

State of Texas,

Appellee On Appeal from Cause No. 2013-0731in the 159th

Judicial District Court of Angelina County, Texas State’s First Motion for Extension (Unopposed)

To the Honorable Justices of this Court:

Appellee, State of Texas, moves for a 30-day extension of time to file its

brief.

I.

Undre the Texas Rules of Appellate Procedure, the general deadline to file

an appellee’s brief is 30 days after the date the appellant’s brief was filed. Tex. R.

App. P.38.6(b). Appellant’s Brief was filed on August 24, 2015, giving the State

until Wednesday September 23, 2015 to file its brief.

The State of Texas now requests a 30-day extension of time in which to file

its brief.

II.

Good cause exists for allowing the State additional time to file its brief for

the following reasons:

1. Counsel for the State was working on and completed a brief in Allen

v. State , No. 12-15-00131-CR during the same time frame.

2. Counsel for the State had a week long aggravated sexual assault of a

child trial September 14-18, 2015 in State v. Taylor , case no. 2014-0145 in the

159th Judicial District Court.

3. Counsel for the State is out of town September 22-25, 2015 at a

prosecutor training conference.

4. Counsel for the Appellant is unopposed to this extension.

III.

From the above-listed reasons, the State has demonstrated that good cause

for the failure to be able to submit its brief by the Court’s deadline. This is the

State’s first motion for extension, and it is not brought for purposes of delay or

harrassment, but to see that justice is done.

Wherefore, Appellee State of Texas prays that the Court grant its requested

30-day extension to file its State’s Brief in this matter.

Respectfully Submitted, /s/ April Ayers-Perez Assistant District Attorney Angelina County D.A.’s Office P.O. Box 908 Lufkin, Texas 75902 (936) 632-5090 phone (936) 637-2818 fax State Bar No. 24090975 ATTORNEY FOR THE STATE OF TEXAS Certificate of Service

I certify that on September 23, 2015, a true and correct copy of the above

document has been forwarded to John Reeves, by electronic service through

efile.txcourts.gov.

/s/ April Ayers-Perez *4 Certificate of Conference

I certify that on September 23, 2015, I conferred with John Reeves about this

motion, and certify that he was unopposed to a 30-day extension.

/s/ April Ayers-Perez