Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 12/3/2015 10:42:04 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00302-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 12/3/2015 10:42:04 AM CHRISTOPHER PRINE CLERK CAUSE NO. 01-15-00302-CR IN THE COURT OF APPEALS FOR THE FIRST SUPREME JUDICIAL DISTRICT AT HOUSTON, TEXAS __________________________________________________________________
JASON BURROWS v. THE STATE OF TEXAS __________________________________________________________________
STATE'S MOTION FOR EXTENSION OF TIME TO FILE STATE’S BRIEF
COMES NOW THE STATE OF TEXAS, by and through the
Criminal District Attorney of Brazoria County, Texas, and presents its
Motion for Extension of Time to File State’s Brief and in support thereof
would show the following:
I.
A. TRIAL COURT: Style of case, cause number and trial court.
1. Trial Court: 412th District Court, Brazoria County, Texas
2. Style of Case: Jason Burrows v. The State of Texas
3. Cause No. 74447
B. CHARGES: Official Oppression
C. DEADLINE FOR FILING: December 7, 2015
D. LENGTH OF TIME REQUESTED FOR EXTENSION:
30 days until January 6, 2015.
E. PREVIOUS NUMBER OF EXTENSIONS GRANTED:
No Previous Extensions
II.
Below, I have listed my recently completed projects and projects
due in the near future:
RECENTLY COMPLETED MAJOR PROJECTS
- Evidentiary submission May 13, 2015 in writ of habeas corpus Ex parte
Jose Lomeli , no. 71293-A.
- State’s Answer with accompanying documents to DNA motion on May 26,
2015 on Ex parte Monzelle Steptoe , no. 58852-6.
- Attended Appellate Seminar May 27-29 2015.
- Response to Writ of Mandamus on Re Joshua Tyrone Lane ; nos. 01-15-
00460-CR & 01-15-00461-CR on June 8, 2015.
- Brief filed on the death penalty capital murder case in James Harris, Jr.
v. State of Texas , no. AP-77,029 on August 3, 2015. The majority of my time has
been devoted to this very long and involved brief with by far the longest record I
have ever dealt with.
-Discovery hearing on capital murder 11.071 writ in Ex parte James Harris,
Jr. , no. 67063-A on August 17, 2015. This State’s attorney will be responsible for
handling all matters on this 11.071 writ.
-Response filed on quasi– Anders brief on Trumaine Williams v. State , no.
14-15-00262-CR on August 25, 2015.
-Brief filed on Bridget Miller v. State , no. 01-14-00930-CR on August 31,
2015.
-Brief filed on Andrew Allen , nos. 14-15-00115-CR; 14-15-00116-CR on
October 7, 2015.
-Brief filed on Dorsey Nathaniel Carr , no. 01-15-00246-CR on October 21,
2015.
-Evidentiary submission on 11.07 writ on Lawrence Silva , no. 46816-A on
November 5, 2015.
-Brief filed on Jordan Nichols , no. 14-15-00259-CR on November 17,
2015.
-DNA motion response on Thomas Moreland , 54671-2 filed November 20,
2015.
-Vacation November 23-27, 2015 (first vacation for the year).
-Preparing and filing answers and findings on a number of writ of habeas
corpus; preparing research for the District Attorney and trial counsel on numerous
occasions; various administrative matters; and presenting new appellate opinions
for staff meetings.
MAJOR PROJECTS DUE IN NEAR FUTURE
-Brief due on Tamara Hines , no. 14-15-00325-CR on December 28, 2015
(One extension granted).
-Brief due on Jason Burrows , no. 01-15-00302-CR on December 7, 2015
(Current case).
-Brief due on Joshua Plaster , no. 14-15-00522-CR on December 21, 2015.
In addition to the above major projects this attorney is responsible
for the more minor, but nonetheless time consuming day to day work, set
out below.
I am responsible for handling felony, misdemeanor, and juvenile appeals;
11.07, 11.09, 11.071, and 11.072 writs of habeas corpus; reviewing mandated
cases to verify the defendants’ sentencing setting; motions for DNA testing;
continuing legal education for the trial attorneys; and aiding trial counsel and the
District Attorney in legal research immediately before and during trial. This
Motion is made so that justice may be done in this cause, and not for purposes of
delay.
WHEREFORE, PREMISES CONSIDERED , the State prays that the
Court grant this Extension of Time to File State’s Brief.
Respectfully submitted, /S/ DAVID BOSSERMAN DAVID BOSSERMAN Assistant District Attorney 111 E. Locust, Suite 408A Angleton, Texas 77515 (979) 864-1232; fax (979) 864-1525 Bar Card No. 02679520 davidb@brazoria-county.com THE STATE OF TEXAS §
COUNTY OF BRAZORIA §
BEFORE ME, the undersigned authority, on this day personally appeared
DAVID BOSSERMAN, Attorney for the State herein, and states on his oath that
he has read all of the foregoing document and allegations of fact contained therein,
and states he knows that within his own knowledge, the same are true and correct.
/S/ DAVID BOSSERMAN DAVID BOSSERMAN *5 SUBSCRIBED TO AND SWORN TO BEFORE ME, on this the 3 rd day of
December, 2015 to certify which, witness my hand and seal of office.
/S/ MYRLIN LESIKAR MYRLIN LESIKAR, NOTARY PUBLIC Commission Exp. FEB. 28, 2017 CERTIFICATE OF SERVICE The undersigned Attorney for the State of Texas certifies that a true copy of
this motion was served by e-filing in accordance with Rule 9.5 of the Rules of
Appellate Procedure on Appellant’s attorney, Scot R. Courtney, P.O. Box 787, San
Marcos, Texas 78667-0787; e-mail sanmarcoslaw@gmail.com, on this 3 rd day of
December, 2015.
/S/ DAVID BOSSERMAN DAVID BOSSERMAN