Cordero Brown v. State ( 2015 )


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  •                                                                                            ACCEPTED
    06-14-00115-CR
    SIXTH COURT OF APPEALS
    TEXARKANA, TEXAS
    3/20/2015 1:44:03 PM
    DEBBIE AUTREY
    CLERK
    CAUSE NO. 06-14-00115-CR
    CORDERO BROWN                           §     IN THE COURT OF     APPEALS
    FILED IN
    6th COURT OF APPEALS
    §                  TEXARKANA, TEXAS
    VS.                                     §IN AND FOR THE 3/20/2015
    SIXTH 1:44:03
    DISTRICT
    PM
    §                    DEBBIE AUTREY
    THE STATE OF TEXAS                      §        OF THE STATEClerk
    OF TEXAS
    STATE'S FIRST MOTION TO EXTEND TIME
    FOR FILING STATE’S BRIEF
    THE STATE OF TEXAS, by and through the undersigned Assistant District
    Attorney, respectfully moves the Court to extend the time for filing of the
    Appellee’s Brief in accordance with Rule 10.5 of the Texas Rules of Appellate
    Procedure. In support of its motion, the State respectfully offers the following:
    1. The Appellee’s brief is due Monday, March 23, 2015, and I have not completed
    it due to other matters with more pressing deadlines.
    2. The State seeks an additional 30 days, until Wednesday, April 22, 2015. The
    undersigned will, nonetheless, attempt to complete and file the State’s brief
    prior to the extended deadline.
    3. The undersigned attorney is responsible for all post-conviction prosecution for
    the Gregg County Criminal District Attorney’s Office, including direct appeals,
    appeals from justice courts, and applications for habeas corpus.
    In the past 30 days the undersigned attorney has completed the following:
    A.     Appellate Briefs:
    1.    March 4, 2015, Kelly v. State, PD 0702-13
    B.     Responses to Writ Applications:
    1.    Ex parte Larry Means 42561-B-H-?
    WR-16,525-07, February 25, 2015
    2.    Ex parte Ryan Woods, 39,923B H 1, WR 37,856-10, March
    13, 2015
    3.    Ex parte Terry Miller 30,600-A-H-8, WR 37,856-11 March
    16, 2015.
    C.    PDR’s reviewed:
    1.    Palmer v. State, 6-13-00265-CR, February 12, 2015.
    2.    Thomas v. State, 6-14-00002-CR, February 13, 2015.
    In the next 30 days the undersigned attorney must respond to the following
    in addition to this brief:
    A.    Appellate Briefs due:
    1.    Ross v. State, 06-14-00157-CR April 10, 2015
    B.    Due dates for responses, if any, to PDR, after no extensions
    1.    Saddler v. State, 06-14-00175-CR, requested due date:
    March 23, 2015.
    C.    Habeas responses due:
    1.    Ex parte Cline 16,318-A-H-12?, WR-16.199-02, March
    30, 2015
    2.    Ex parte Moises Rentaria 38,802-A-H-1 March 31, 2015
    3.    Ex parte Ladderick Morgan 33,311-B-H-1 March 31,
    2015.
    4.    Ex parte James Pierce 37,630 A-H-3 March 31, 2015
    4. Appellant relies on the following facts as good cause for the requested
    extension:
    a. During the past 30 days, the undersigned has submitted an appellate brief,
    and four habeas responses, as shown above.
    b. I have also read the brief and the 10-volume record in this case, but I have
    not finished writing the brief.
    c. No previous extensions have been requested by the State in this case.
    d. This extension is not requested for purposes of delay, but so that justice may
    be done.
    Respectfully submitted,
    /s/Zan Colson Brown
    Zan Colson Brown
    Texas Bar No. 03205900
    Assistant Criminal District Attorney
    101 East Methvin St., Suite 333
    Longview, TX 75601
    Telephone: (903) 236–8440
    Facsimile: (903) 236–3701
    E-mail: zan.brown@co.gregg.tx.us
    CERTIFICATE OF SERVICE
    I certify that a true and correct copy of the above and foregoing has been
    forwarded to appellant by e-service addressed to Mr. Lew Dunn at
    dunn@texramp.com.
    This 20th day of March, 2015.
    /s/ ZanColsonBrown
    Zan Colson Brown
    Assistant Criminal District Attorney
    

Document Info

Docket Number: 06-14-00115-CR

Filed Date: 3/20/2015

Precedential Status: Precedential

Modified Date: 9/29/2016