Zane Lynn Barton v. State ( 2015 )

ACCEPTED 03-14-00559-CR 5402647 THIRD COURT OF APPEALS AUSTIN, TEXAS 5/22/2015 3:23:09 PM JEFFREY D. KYLE CLERK No. 03-14-00559-CR Court of Appeals FILED IN 3rd COURT OF APPEALS for the AUSTIN, TEXAS Third Supreme Judicial District of Texas 5/22/2015 3:23:09 PM JEFFREY D. KYLE At Austin Clerk Zane Lynn Barton, Appellant VS. The State of Texas, Appellee Appeal From 274th District Court of Hays County, Texas Trial Court Cause Number CR-13-0614 First Motion For Extension of Time in Which to File State's Brief Laura Garcia Asst. Criminal District Attorney Hays County Government Center 712 South Stagecoach Trail, Ste. 2057 San Marcos, Texas, 78666 512-393-7600 laura. garcia@co.hays .tx.us State Bar No. 24074249 Attorney for the State of Texas TO THE HONORABLE JUSTICES OF THE THIRD COURT OF APPEALS: The State files this First Motion for Extension of Time in Which to File State's Brief, and in support states: 1. The State's current deadline for filing its brief is May 22, 2015. 2. This is the State's first Motion for Extension of Time in which to file her brief 3. The State respectfully requests an extension of approximately forty- five days, until July 6, 2015 in which to file her brief 4. Good cause exists for the State's request for extension of time in which to file its brief The undersigned attorney is working on possible agreed supplement of the record. 5. These circumstances have significantly delayed the completion of this brief 6. This extension is not being sought to cause undue delay, but to seek justice. 7. For the foregoing reasons, the State respectfiilly requests that the Court grant an approximate thirty day extension for filing Appellee's Brief, until July 6, 2015. Respectfully submitted. ira Garch Asst. Criminal District Attorney Hays County Government Center 712 South Stagecoach Trail, Ste. 2057 San Marcos, Texas, 78666 512-393-7600 laura.garcia@co.hays.tx.us State Bar No. 24074249 Attorney for the State, of Texas The foregoing Appellant Motion for Extension of Time in Which to File Appellant's Brief was subscribed and sworn to before me by Laura Garcia on this the 22nd of May, 2015. Laura jGarcia RHONDA WIEDERSTEIN >1 MY COMMISSION EXPIRES Septembers, 2018 Notary Public in and for the State of Texas CERTIFICATE OF SERVICE I certify that on May 22, 2015, I served the above motion by email to Amanda Erwin at amanda@theerwinlawfirm.com, in accordance with the Texas Rules of Appellate Procedure.