Jason Robert Vanwinkle v. State

Opinion

ACCEPTED

04-14-00762-CR

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

5/19/2015 9:36:19 AM

KEITH HOTTLE

CLERK

No. 04-14-00762-CR

IN THE COURT OF APPEALS FOR THE FOURTH JUDICIAL DISTRICT OF TEXAS, AT SAN ANTONIO

FILED IN

4th COURT OF APPEALS

Jason Robert Vanwinkle SAN ANTONIO, TEXAS Appellant 5/19/2015 9:36:19 AM KEITH E. HOTTLE

v. Clerk

The State of Texas

Appellee

On Appeal from the 198th District Court of Bandera County Cause No. CR-14-0000041

The Honorable M. Rex Emerson, Judge Presiding

Motion for Extension of Time To File State’s Brief on Appeal

TO THE HONORABLE FOURTH COURT OF APPEALS:

COMES NOW, the State of Texas, Appellee in the above styled and numbered cause, by and through her duly elected District Attorney, and respectfully enters this “Motion for Extension of Time to File State's Brief on Appeal,” and in support of such Motion would show the Court:

I

Appellant was convicted in the 198th District Court of Bandera County, Texas, of the offense of Arson. Punishment was assessed at confinement for 50 years. The trial court imposed sentence on September 25, 2014, and notice of appeal was timely filed with the clerk of the trial court. The deadline for filing the State's Brief with the Court is May 20, 2015. This request for an extension is based upon the inability of the undersigned attorney to finish research on the issues raised by the trial of the case.

II

Counsel for the State would further show that he will require an additional forty-five (45) days in which to complete the research and prepare the State's Brief. This is the State's first request for an extension of time in which to file its brief.

Prayer

WHEREFORE PREMISES CONSIDERED, the undersigned prays this Honorable Court to grant the State's motion for extension of time in which to file its brief, and Order that the deadline for filing such be extended an additional forty-five (45) days, until July 6, or until such time as set by this Court.

Respectfully submitted,

/s/ Scott F. Monroe

_________________________________________

Scott F. Monroe District Attorney, 198th District Court 402 Clearwater Paseo, Suite 500 Kerrville, Texas 78028 eMail: scottm@198da.com Tel. 830-315-2460 Fax: 830-315-2461 State Bar Card No. 14272700 Attorney for the State of Texas

Certificate of Compliance and Delivery This is to certify that: (1) this document, created using WordPerfect™ X7 software, contains 341 words, excluding those items permitted by Rule 9.4 (i)(1), Tex.R.App.Pro., and complies with Rules 9.4 (i)(2)(B) and 9.4 (i)(3), Tex.R.App.Pro.; and (2) on May 19, 2015, a true and correct copy of the above and foregoing “Motion for Extension of Time To File State's Brief on Appeal” was transmitted via the eService function on the State’s eFiling portal, to M. Patrick Maguire (mpmlaw@ktc.com), counsel of record for Appellant.

/s/ Scott F. Monroe

_________________________________________

Scott F. Monroe