Case Information

*0 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 5/22/2015 9:59:06 AM JEFFREY D. KYLE Clerk 03-14-00516-CR NO. THIRD COURT OF APPEALS 5/22/2015 9:59:06 AM JEFFREY D. KYLE AUSTIN, TEXAS 03-14-00516-CR *1 ACCEPTED ^[5392484] CLERK MARK ANTHONY SERRANO IN THE

v. THIRD COURT OF APPEALS

THE STATE OF TEXAS AUSTIN, TEXAS

STATE'S MOTION FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE THIRD COURT OF APPEALS:

NOW COMES the State of Texas, Appellee in the above entitled and

numbered cause and files this Motion for Extension of Time to File

Appellee's Brief, and in support thereof would show the Court the following:

I.

Appellant was found guilty of Theft Over $20,000, a Third Degree

felony enhanced as a Habitual Offender, and the Jury assessed punishment

at 25 years confinement in the Texas Department of Criminal Justice on

June 19, 2014. Appellant filed Notice of Appeal on August 20, 2014.

Appellant's brief was filed on April 22, 2015. Appellant's amended brief was

filed on May 12, 2015. The State's brief is currently due on May 22,2015.

II.

The State has not requested an extension in this case prior to this

request.

III.

The State requests this extension of time due to the following: Counsel

for the State has been preparing for jury trial and is currently trying a

continuous sexual assault of a child case in State v. Miguel Davila, Cause

Number D-14-0826-SA, which began on May 18, 2015. Additionally,

Counsel for the State has been involved in prosecution of cases including

*2 contested hearings, pretrial hearings, grand jury presentation, negotiations

with opposing counsel, guilty pleas and other hearings in numerous

additional pending felony cases.

WHEREFORE, The Attorney for the State requests an extension of

time to July 24,2015, in which to file State's Brief.

John est

Assistant District Attorney 51 st Judicial District 124 W. Beauregard, Suite B San Angelo, TX 76903 (325) 659-6583 State Bar No. 00796203 SWORN TO AND SUBSCRIBED before me by the said John Best,

this fL-flIJ day of May, A. D. 2015.

&z ~'~ {-!::X:::t~ Notary Public. State of Texas ~ .0 f "d ~~~~Yftz',~ CHRISTINE GEORGE (~ Notary Public

'\t1;l5.{f..! My Commission Expires State of Texas ··,·7,,70;,'-''''' June 28, 2016

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the/oregoing Motion for

Extension of Time to File Appellee's Brief was this t~{t .... day of May, 2015,

delivered to Randol Stout, at rls2700@gmail.com, Attorney for Appellant,

through e-file.txcourts.gov.