Christopher Rivera v. State

Opinion

ACCEPTED 03-15-00116-CR 6375344 THIRD COURT OF APPEALS AUSTIN, TEXAS 8/5/2015 4:47:38 PM JEFFREY D. KYLE CLERK NO. 03-15-00116-CR

COURT OF appeals FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS FOR THE 8/5/2015 4:47:38 PM JEFFREY D. KYLE AUSTIN SUPREME JUDICIAL DISTRICT Clerk

CHRISTOPHER QUINN RIVERA, Appellant

VS.

THE STATE OF TEXAS, Appellee

APPEAL FROM

THE 428TH JUDICIAL DISTRICT COURT

HAYS COUNTY, TEXAS

TRIAL COURT CAUSE NO. CR-14-0448

First Motion For Extension of Time in Which to File State's Brief

John Couch Assistant Criminal District Attorney 712 S. Stagecoach Trail, Suite 2057 San Marcos, Texas 78666 Ph: (512) 393-7600 / Fax: (512) 393-2246 State Bar No. 24048407 john.couch@co.hays.tx.us 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 August 7, 2015. 2. This is the State's first request for an extension of time in which to file

its brief

3. The State respectfully requests an extension of approximately thirty days, until September 6, 2015 in which to file its brief. 4. Good cause exists for the State's request for extension of time in which to file its brief The attorney of record is currently the prosecutor in a felony jury trial.

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 respectfully requests that the Court grant an approximate thirty day extension for filing Appellee's Brief, until September 6, 2015. Respectfully submitted,

2/ Jo^ Couch ^ Assistant Criminal District Attorney Hays County Government Center 712 South Stagecoach Trail, Ste. 2057 San Marcos, Texas, 78666 Tel: 512-393-7600 John.couch@co.hays.tx.us State Bar No. 24048407 Attorney for the State of Texas

VERIFICATION

The foregoing Appellant Motion for Extension of Time in Which to File Appellant's Brief was subscribed and sworn to before me by John Couch onthis ^ ,2015.

John C6uch Assistant Criminal District Attorney RHONDA WEDERSTEIN MY COMMISSION EXPIRES Sept8mber9,2018

Notary Public in and for the State of Texas CERTIFICATE OF SERVICE

I certify that on ^ , 2015, I served the above motion by email to Rickey D. Jones at rickey@satx.rr.com, in accordance with the Texas Rules of Appellate Procedure.

John 06uch Assistant Criminal District Attorney