Jeffrey Arlen Quinn v. State ( 2015 )

ACCEPTED
12-14-00263-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
6/17/2015 4:10:27 PM
CATHY LUSK
CLERK
COURT OF AI'PEAl.s NO. 12· 14·00263·CR
TRIAL COURT CAUSE NO. C·20,SUI
FILED IN
12th COURT OF APPEALS
JHFREY AKI.EN QUINN, )( IN THE \2'-11TYLER,
COURT TEXAS
API'U,LANT 6/17/2015 4:10:27 PM
CATHY S. LUSK
VS. OF APPEALS Clerk
TIlE STA1"E OJ" TEXAS,
API'ELLEE x TYLER, TEXAS
MOTIO N FOR EXTENSION OF TIM E TO FILE AI'I'ELLEE'S HRI E..•
TO TIm 1I0NORAHU: J UDG ~:S 0'" SAil> COU RT:
COMES NOW. the APPELL EE State ofTe~as. by and through her Assistant District
Allomey. Mark W. Hall, and files th is Motion for E)(ten~ion of T imc to File Appellee'~ Brief and
in suppon of the same wou ld show the following:
I. Th is case is on appeal from the J" Judicial District Coun of Henderson County.
Texas.
2. llJc style and number of the case in the Trial Court is The Stille o/Texas ~·s. Jeffrey
Arlen Quinn, Cause Number C-20,8 18.
3. The Appellant was found guilty to the offense of Evading Arrest with a Motor
Vehicle. with Enhancements which were found true. in add it ion to an aff,rmati,'C
finding thal a deadly weapon was used. Appellant elected to have the j ury assess
punishment. and on June 19. 20 14. the jury sentenced Appellant to sevent een (17)
years in TOCJ· lnstitutional prm·ision. and he appealed.
4. Appellee's brief was due on June 15. 2015. and Appellcc has nO! requested any prior
extensions to file his brief.
5. Appellee requests an additional extension of time for the followi ng reasons
Page 1
a. Undersigned Coun-el needs addili onallime to conducl research and comp lete
lhe Slalc's bricf.
b. Counsel is preparing for a civil. CPS jury trial in lhe 392" Judiclal Di'lricl
Court styled In the Intcrest of Dwighl Durrell, a Chil d. Cau!.!: 1\0. 2014 B-00S4.
selto begin June 22. 2015.
c. In addition. undersig ned counse l is responsible for the dai ly docket work of thf
3'" Judici al District Court. in Ilenderson Coonty. Texas. whic h require, a
, ubstantial amoum of lime.
6. Based on thc aforesaid. coonse l for Appcllcc rcquesl~ additionaltlme 10 complete the
Appcllcc'§ reply brief.
7. The unden.igned is I1QI seeki ng this extension for the purpo:;es of