Mark Anthony Serrano v. State ( 2015 )

ACCEPTED 03-14-00516-CR 5392484 THIRD COURT OF APPEALS AUSTIN, TEXAS 5/22/2015 9:59:06 AM JEFFREY D. KYLE CLERK NO. 03-14-00516-CR FILED IN MARK ANTHONY SERRANO IN THE 3rd COURT OF APPEALS AUSTIN, TEXAS 5/22/2015 9:59:06 AM v. THIRD COURT OF APPEALS JEFFREY D. KYLE Clerk THE STATE OF TEXAS AUSTIN, TEXAS STATE'S MOTION FOR EXTENSION OF TIME TO FILE BRIEF TO THE HONORABLE THIRD COURT OF APPEALS: NOW COMES the State of Texas, Appellee in the above entitled and numbered cause and files this Motion for Extension of Time to File Appellee's Brief, and in support thereof would show the Court the following: I. Appellant was found guilty of Theft Over $20,000, a Third Degree felony enhanced as a Habitual Offender, and the Jury assessed punishment at 25 years confinement in the Texas Department of Criminal Justice on June 19, 2014. Appellant filed Notice of Appeal on August 20, 2014. Appellant's brief was filed on April 22, 2015. Appellant's amended brief was filed on May 12, 2015. The State's brief is currently due on May 22,2015. II. The State has not requested an extension in this case prior to this request. III. The State requests this extension of time due to the following: Counsel for the State has been preparing for jury trial and is currently trying a continuous sexual assault of a child case in State v. Miguel Davila, Cause Number D-14-0826-SA, which began on May 18, 2015. Additionally, Counsel for the State has been involved in prosecution of cases including contested hearings, pretrial hearings, grand jury presentation, negotiations with opposing counsel, guilty pleas and other hearings in numerous additional pending felony cases. WHEREFORE, The Attorney for the State requests an extension of time to July 24,2015, in which to file State's Brief. John est Assistant District Attorney 51 st Judicial District 124 W. Beauregard, Suite B San Angelo, TX 76903 (325) 659-6583 State Bar No. 00796203 SWORN TO AND SUBSCRIBED before me by the said John Best, this fL-flIJ day of May, A. D. 2015. {-!::X:::t~ ````Yftz',~ CHRISTINE GEORGE Notary Public. State of Texas &z ~ ~'~ .0f"d (~ '\t1;l5.{f..! My Commission Expires Notary Public ··,·7,,70;,'-' ' ' June 28, 2016 State of Texas CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the/oregoing Motion for Extension of Time to File Appellee's Brief was this t~{t . . day of May, 2015, delivered to Randol Stout, at rls2700@gmail.com, Attorney for Appellant, through e-file.txcourts.gov.