Billy Jack Vercher v. State

• Court: Court of Appeals of Texas
• Decided: January 16, 2015
• Docket: 03-13-00799-CR
• Status: Published

Opinion

ACCEPTED 03-13-00799-CR 3799017 THIRD COURT OF APPEALS AUSTIN, TEXAS 1/16/2015 1:37:22 PM JEFFREY D. KYLE CLERK NO.03-13-00799-CR

BILLY JACK VERCHER IN THE FILED IN V. 3rd COURT THIRD COURT OF APPEALS OF APPEALS AUSTIN, TEXAS 1/16/2015 1:37:22 PM THE STATE OF TEXAS AUSTIN, TEXAS JEFFREY D. KYLE Clerk

STATE'S FIRST 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 First 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 by a jury of Aggravated Robbery, a First Degree felony

enhanced to a 15-99, and the Judge assessed punishment at 30 years confinement in

the Texas Department of Criminal Justice. Appellant was granted new counsel on June

27,2014. Appellant's brief was filed on December 17,2014. The State's brief is currently

due on January 16, 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 involved in prosecution of felony cases including contested hearings,

pretrial hearings, grand jury presentation, negotiations with opposing counsel, guilty pleas

and other hearings in numerous additional pending felony cases. In addition, the State

has been preparing several jury cases for January 26, 2015. WHEREFORE, The Attorney for the State requests an extension of thirty (30) days

to February 16, 2015, in which to file State's Brief.

Respectfully submitted,

bC-~.~ <:JaJ1iFergu~ &>

Assistant District Attorney 51 st/119th Judicial District 124 W. Beauregard, Suite B San Angelo, TX 76903 (325) 659-6583 State Bar No. 24072092

SWORN TO AND SUBSCRIBED before me by the said Jason Ferguson, this 16th day of January, A. D. 2015. ...,~

ril!1i::;.\ Nota7yH~~~i:~.Es~~~~~iexas ~~~ Notary Public ;.'.~/., Commission Expires My State of Texas \~~'OF~~~ ",,,,,,,\~ June 28, 2016

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing Motion for Extension

of Time to File Appellee's Brief was this 16th day of January, 2015, delivered to Melvin

Gray, Attorney for Appellant, through e-file .txcourts.gov