Dequisha Jackson v. State

Opinion

ACCEPTED

12-15-00003-CR

TWELFTH COURT OF APPEALS

TYLER, TEXAS

9/23/2015 10:46:49 PM

Pam Estes

CLERK

Cause No. 12-15-00003-CR

FILED IN

12th COURT OF APPEALS

TYLER, TEXAS

In the Court of Appeals for the 9/23/2015 10:46:49 PM

Twelfth Judicial District at Tyler, Texas PAM ESTES Clerk

Dequisha Jackson,

Appellant

v.

State of Texas,

Appellee

On Appeal from Cause No. 2013-0731in the 159th Judicial District Court of Angelina County, Texas

State’s First Motion for Extension (Unopposed)

To the Honorable Justices of this Court:

Appellee, State of Texas, moves for a 30-day extension of time to file its brief.

I.

Undre the Texas Rules of Appellate Procedure, the general deadline to file an appellee’s brief is 30 days after the date the appellant’s brief was filed. Tex. R.

2

App. P.38.6(b). Appellant’s Brief was filed on August 24, 2015, giving the State until Wednesday September 23, 2015 to file its brief.

The State of Texas now requests a 30-day extension of time in which to file its brief.

II.

Good cause exists for allowing the State additional time to file its brief for the following reasons:

1. Counsel for the State was working on and completed a brief in Allen v. State, No. 12-15-00131-CR during the same time frame.

2. Counsel for the State had a week long aggravated sexual assault of a child trial September 14-18, 2015 in State v. Taylor, case no. 2014-0145 in the 159th Judicial District Court.

3. Counsel for the State is out of town September 22-25, 2015 at a prosecutor training conference.

4. Counsel for the Appellant is unopposed to this extension.

III.

From the above-listed reasons, the State has demonstrated that good cause for the failure to be able to submit its brief by the Court’s deadline. This is the State’s first motion for extension, and it is not brought for purposes of delay or harrassment, but to see that justice is done.

3

Wherefore, Appellee State of Texas prays that the Court grant its requested 30-day extension to file its State’s Brief in this matter.

Respectfully Submitted,

/s/ April Ayers-Perez

Assistant District Attorney Angelina County D.A.’s Office P.O. Box 908

Lufkin, Texas 75902

(936) 632-5090 phone

(936) 637-2818 fax

State Bar No. 24090975

ATTORNEY FOR THE

STATE OF TEXAS

Certificate of Service

I certify that on September 23, 2015, a true and correct copy of the above document has been forwarded to John Reeves, by electronic service through efile.txcourts.gov.

/s/ April Ayers-Perez

4

Certificate of Conference I certify that on September 23, 2015, I conferred with John Reeves about this motion, and certify that he was unopposed to a 30-day extension.

/s/ April Ayers-Perez