Cody Crymes v. State

Opinion

ACCEPTED

01-15-00206-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS 10/15/2015 4:01:05 PM CHRISTOPHER PRINE

CLERK

No. 01-15-00206-CR

IN THE COURT OF APPEALS FILED IN 1st COURT OF APPEALS

HOUSTON, TEXAS

FIRST JUDICIAL DISTRICT 10/15/2015 4:01:05 PM CHRISTOPHER A. PRINE

HOUSTON, TEXAS Clerk

__________________________________________________________

No. 17166

IN THE 253RD DISTRICT COURT OF

CHAMBERS COUNTY, TEXAS

__________________________________________________________

CODY CRYMES § Appellant

v. §

STATE OF TEXAS § Appellee

__________________________________________________________

STATE'S MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO

APPELLANT’S MOTION FOR REHEARING

__________________________________________________________

Cheryl Swope Lieck District Attorney Chambers County, Texas

Kathy Esquivel Assistant District Attorney Chambers County, Texas P.O. Box 1409 Anahuac, Texas 77514 (409) 267-2682 (409) 267-3105 kesquivel@co.chambers.tx.us

COMES NOW the State of Texas, by and through her Assistant District Attorney, Kathy Esquivel, and, pursuant to TEX. R. APP. PRO. 73, presents this Motion for Extension of Time. In support of the motion, the State submits the following:

1. The above case is on appeal from a plea of guilty in the 253rd Judicial District Court of Chambers County, Texas.

2. The State’s response is currently due on October 20, 2015.

3. This is the State’s first Motion for Extension of Time.

4. Counsel for the State was preparing for another jury trial in the 253rd District Court and did not have adequate time to complete the brief in this case. Further, counsel for the State was preparing a case for a special meeting of the grand jury.

5. The State requests that the time for filing the State’s Brief be extended by 7 days to October 27, 2015. The State requests this extension not for delay, but to see that justice is done.

WHEREFORE, PREMISES CONSIDERED, the State prays that this

Court grant the State’s Motion for Extension of Time and extend the due date of the

State’s Appellate Brief until October 27, 2015.

Respectfully submitted, CHERYL SWOPE LIECK Chambers County District Attorney

/s/ Kathy Esquivel KATHY ESQUIVEL Assistant District Attorney

Chambers County, Texas P.O. Box 1409 Anahuac, Texas 77514 (409) 267-2682 (409) 267-3105 FAX SBN 24034432 kesquivel@co.chambers.tx.us

CERTIFICATE OF SERVICE

This is to certify that a copy of the foregoing instrument has been sent to opposing counsel via email on ___15th_____ day of October, 2015.

/s/ Kathy Esquivel KATHY ESQUIVEL Assistant District Attorney Chambers County, Texas

Rick Oliver Attorney for Appellant