Jim Jack Thompson, III v. State ( 2015 )

ACCEPTED
03-14-00371-CR
6045947
THIRD COURT OF APPEALS
AUSTIN, TEXAS
7/13/2015 4:44:17 PM
JEFFREY D. KYLE
CLERK
NO. 03-14-00371-CR
JIM JACK THOMPSON § IN THE COURT OF APPEALS
FILED IN
3rd COURT OF APPEALS
§ AUSTIN, TEXAS
v. § THIRD DISTRICT
7/13/2015 4:44:17 PM
§ JEFFREY D. KYLE
Clerk
STATE OF TEXAS § AUSTIN, TEXAS
SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF
NOW COMES THE STATE OF TEXAS, Appellee, by and through her
Assistant District Attorney, John C. Prezas, and moves the Court, pursuant to Texas
Rule of Appellate Procedure 38.6(d), to extend the deadline for filing the State’s brief.
In support of its motion, the State would show the Court the following:
1. The State’s Brief in this case is due on July 14, 2015. The State has requested, and
this Court has granted, one previous extension of time.
2. Appellant’s brief was filed in this Court on April 14, 2015.
3. Mr. Prezas recently filed the State’s proposed findings of fact and conclusions of
law in the following habeas corpus proceedings: Ex Parte Santos Loa 86-252-KC;
Ex Parte Ramon Cavazos Jr. 07-1628-K277A; Ex Parte Troy Dale Mansfield 92-
435-K277A; Ex Parte Rolando Bacon Lopez, 10-1053-K368A; Ex Parte Robert
Jesse Padilla, 06-937-K368A; Ex Parte Robert Jesse Padilla, 06-921-K368A; Ex
Parte Daniel Robert Lock, 94-085-K277A; Ex Parte Daniel Robert Lock 97-780-
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K277A.
4. Mr. Prezas has recently filed answers in the following habeas corpus proceedings:
Ex Parte William Johnson 88-405-KF, Ex Parte Joseph Paul Mayzone 93-070-
K277A,Ex Parte Steven M. Ruiz 12-1097-K26A, Ex Parte Victor Manuel Soto 13-
1581-K26A, Ex Parte Edwin Gus Schneider 10-960-K26A,and Ex Parte Timothy
Jerrold Kipp 13-0658-K277A and 13-0622-K277A.
5. Mr. Prezas is currently meeting with attorneys to gather affidavits in anticipation of
filing proposed findings of fact and conclusions of law in the habeas proceedings of
Ex Parte Wendi Ann Tillman 06-1062-K368A.
6. Mr. Prezas filed a State’s brief on May 21, 2015, in response to the Court of
Criminal Appeals granting the State’s petition for discretionary review in John Alan
Wachtendorf, PD-0280-15. Mr. Prezas submitted a State’s Motion to Dismiss in
State vs. Gregory Michael Klapesky 03-15-00244-CR on June 5, 2015.
7. Currently, Mr. Prezas is evaluating a request for DNA testing under Chapter 64 in
03-1063-K277 State vs. Gregory Michael Klapesky.
8. For the foregoing reasons, The State respectfully requests that the deadline for
filing its brief in the above stated cause be extended for an additional sixty two
(62) days from the current due date of July 14, 2015, to September 14, 2015.
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WHEREFORE, PREMISES CONSIDERED, the State of Texas respectfully
requests that this Court grant its motion for an extension of time and extend the State’s
deadline to file its brief to September 14, 2015.
Respectfully submitted,
Jana Duty
District Attorney
Williamson County, Texas
/s/ John C. Prezas
John C. Prezas
Assistant District Attorney
State Bar Number 24041722
405 Martin Luther King #1
Georgetown, Texas 78626
(512) 943-1248
(512) 943-1255 (fax)
jprezas@wilco.org
Certificate of Service
This is to certify that on July 13, 2015, a copy of the foregoing motion has been
sent to Appellant’s attorney of record, Ray Bass, 120 W. 8th street, Georgetown, TX
78626, by eservice at ray@raybass.com.
/s/ John C. Prezas
John C. Prezas
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