Jonathan Matthew Escobedo v. State

Opinion

ACCEPTED 04-14-00904-cr

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS 11/13/2015 3:50:25 PM

KEITH HOTTLE

CLERK

No. 04-14-00904-CR

IN THE COURT OF APPEALS

FILED IN

FIRST COURT OF APPEALS DISTRICT OF TEXAS 4th COURT OF APPEALS HOUSTON, TEXAS SAN ANTONIO, TEXAS 11/13/15 3:50:25 PM

____________________________________________________________

KEITH E. HOTTLE

JOHNATHAN MATTHEW ESCOBEDO, Clerk

Appellant

v.

THE STATE OF TEXAS,

Appellee

______________________________________________________________________________

On Appeal from the 81st/218th District Court Atascosa County, Texas Cause Number 13-09-0117-CRA

______________________________________________________________________________

STATE’S MOTION FOR EXTENSION OF TIME TO FILE BRIEF

______________________________________________________________________________

Rene M. Pena District Attorney 81st JUDICIAL DISTRICT OF TEXAS

Marc Ledet Assistant District Attorney 81st / 218th JUDICIAL DISTRICT OF TEXAS 1327 3RD STREET Floresville, Texas 78026 Tele: (830) 393-2200 Fax: (830) 393-2205 E-Mail: marcledet@81stda.org State Bar No. 24002459

Attorneys for the State of Texas

STATE’S FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF

The State of Texas, under the authority of Rules 10.5(b) and 38.6(d), Texas Rules

of Appellate Procedure asks the Court to extend time to file the State’s Brief from

NOVEMBER 13, 2015, up to and including NOVEMBER 20, 2015, a period of seven (7)

days.

1. Appellant was found guilty in Atascosa County, Texas for Murder.

2. The State’s Brief is presently due on NOVEMBER 13, 2015.

3. The State of Texas respectfully requests an additional seven (7) days to file its

brief, that is, an extension of time until November 20, 2015.

4. Only one previous extension has been requested by the State, and this its second\

and last extension, is only for 7 days more.

5. The State of Texas requests this extension based on the following reasons:

A. The 81st Judicial District Attorney’s Office covers five (5) counties and

over two hundred miles. Our office does not have an appellate section.

All appellate work is done at times when prosecutors are not in court, not

preparing for trial, or not preparing for grand jury.

B. The State was delayed in receiving a copy of Appellant’s brief and also has

a special Grand Jury scheduled for Monday, November 16, 2106.

C. For these reasons, the State asks the Court to grant an extension of thirty

(30) days to November 13, 2015, within which the State may file its brief

in this cause.

Respectfully submitted,

Rene M. Pena District Attorney 81st JUDICIAL DISTRICT OF TEXAS TEXAS BAR NUMBER 00792752

/S/ MARC LEDET Marc Ledet Assistant District Attorney 81st JUDICIAL DISTRICT OF TEXAS 1327 3RD STREET Floresville, Texas 78026 Telephone (830) 393-2200 Telecopier (830) 393-2205 TEXAS BAR NUMBER 24002459

Attorneys for the State of Texas

Certificate of Service

I hereby certify that the above and foregoing was sent to Richard Langlois, 217 Ardent Grove, San Antonio, TX 78215 on the 13th day of November, 2015 in accordance with the Texas Rules of Procedure.

/S/ Marc Ledet