Jeffrey Arlen Quinn v. State

Opinion

ACCEPTED

12-14-00263-CR

TWELFTH COURT OF APPEALS

TYLER, TEXAS

6/17/2015 4:10:27 PM

CATHY LUSK

CLERK

COURT OF AI'PEAl.s NO. 12· 14·00263·CR TRIAL COURT CAUSE NO. C·20,SUI

FILED IN

12th COURT OF APPEALS

JHFREY AKI.EN QUINN, )( IN THE \2'-11TYLER, COURT TEXAS

API'U,LANT 6/17/2015 4:10:27 PM CATHY S. LUSK

VS. OF APPEALS Clerk

TIlE STA1"E OJ" TEXAS, API'ELLEE x TYLER, TEXAS

MOTIO N FOR EXTENSION OF TIM E TO FILE AI'I'ELLEE'S HRI E..• TO TIm 1I0NORAHU: J UDG ~:S 0'" SAil> COU RT:

COMES NOW. the APPELL EE State ofTe~as. by and through her Assistant District Allomey. Mark W. Hall, and files th is Motion for E)(ten~ion of T imc to File Appellee'~ Brief and in suppon of the same wou ld show the following:

I. Th is case is on appeal from the J" Judicial District Coun of Henderson County.

Texas.

2. llJc style and number of the case in the Trial Court is The Stille o/Texas ~·s. Jeffrey Arlen Quinn, Cause Number C-20,8 18.

3. The Appellant was found guilty to the offense of Evading Arrest with a Motor Vehicle. with Enhancements which were found true. in add it ion to an aff,rmati,'C finding thal a deadly weapon was used. Appellant elected to have the j ury assess punishment. and on June 19. 20 14. the jury sentenced Appellant to sevent een (17)

years in TOCJ· lnstitutional prm·ision. and he appealed.

4. Appellee's brief was due on June 15. 2015. and Appellcc has nO! requested any prior extensions to file his brief.

5. Appellee requests an additional extension of time for the followi ng reasons

Page 1

a. Undersigned Coun-el needs addili onallime to conducl research and comp lete lhe Slalc's bricf.

b. Counsel is preparing for a civil. CPS jury trial in lhe 392"" Judiclal Di'lricl Court styled In the Intcrest of Dwighl Durrell, a Chil d. Cau!.!: 1\0. 2014 B-00S4.

selto begin June 22. 2015.

c. In addition. undersig ned counse l is responsible for the dai ly docket work of thf 3'" Judici al District Court. in Ilenderson Coonty. Texas. whic h require, a , ubstantial amoum of lime.

6. Based on thc aforesaid. coonse l for Appcllcc rcquesl~ additionaltlme 10 complete the Appcllcc'§ reply brief.

7. The unden.igned is I1QI seeki ng this extension for the purpo:;es of <klay.

WIIEREFORE. Appellee requeStS that the Court grant this MOlion and e~ tend the deadline for filing Appellee's brief for approxi mately 30 days from this date 10 July 17.20 15.

~,u.deP

Mart W. Hall

Assistant District Auomey 109 W. Cocsicana

Alhens. Texas 75751

Bar. No_ 00798337

Phortf:': 903--675--6100

Fu: 903-675-6196

Pa~c 2

n ; RTIFI CATE OF SE RVI C E

I. MarkW. Hall. do certify that a true and correCI cnpy oflhc foregoing Motion was dcli .. crcd 10 Defendant's Allomcy, Mr.lohn Youngblood on this Ihe nLII day of June 2015, via emai I tran~mi~sion.

Signed Ihis the 17th day of June. 20 15.

Mark W. Hall

P.~c3

STAn: OF TEXAS •

AFFl I)AVTT

Before me. tile undersigned l1OIary. on thi ~ d~y. personally appeared M~rk W. ll all. a person whoM: identity is known to me. After I admllll~tcred an oath to him. upon his ooth.1lc ~aid:

"My name is Mark W . Hall. I am c~p" ble of making this affidavit. The fae" ~tmcd in tl'll" affidavit are within my personal know ledge and arc truc.

I am lhe ~uomey for tile SlalC of Tcxas in Jeffrey Arlcn Quinn "S. The Sl111e of Te~a~ in Coon of Appeals Cause No. 12·1 4'()()263·CR. [have read tile foregoing MOIion to Extend Time to File AppellCt" s Brief and it is true and COlTC(:i."'

Sub!ll:ribcd and sworn [0 before me thi S \l ,.... day of June 17. 201 5

G3t",,~ "t~

NOiMy Pub -State ofTella,