King, Donald Weston

Opinion

PD-0046-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 1/20/2015 5:07:51 PM Accepted 1/22/2015 3:44:31 PM ABEL ACOSTA CLERK

CAUSE No. PD-0046-15

IN THE CRIMINAL COURT OF APPEALS AUSTIN, TEXAS

DONALD WESTON KING, Petitioner/Appellant

VS. January 22, 2015 STATE OF TEXAS, RespondeiWAppellee

FIRST MOTION FOR EXTENSION OF TIME IN WHICH TO FILE STATE’S REPLY TO PETITION FOR DISCRETIONARY REVIEW

To THE HONORABLE JUSTICES OF THE CRIMINAL COURT OF APPEALS: The State files this First Motion for Extension of Time in Which to File State’s Reply to Petition for Discretionary Review, and in support states: i. The State’s current deadline for filing its brief is January 30, 2015.

2. This is the State’s first Motion For Extension of Time in which to file its reply. 3. The State respectfully requests an extension of approximately seven days, until February 6, 2015 in which to file its reply. 4. Good cause exists for the State’s request for extension of time in which to file its reply. Our office has experienced drastic changes in the flow of case assignments due to new administration. This has significantly delayed the completion of this reply. 5. This extension is not being sought to cause undue delay, but to seek justice. 6. For the foregoing reasons, the State respectfully requests that the Court grant an approximate seven-day extension for filing State’s Reply to Petition for Discretionary Review until February 6, 2015.

Respectfully submitted,

nifer Stlbaum sistan C iminal District Attorney ays Co ty, Texas ays County Government center 712 South Stagecoach Trail, Ste. 2057 San Marcos, Texas 78666 jennifer.stalbaum@co.hays.tx.us (512) 393-7600 (512) 393-2246 fax State Bar No. 24079383 COUNSEL FOR APPELLEE The foregoing Appellant Motion for Extension of Time in Which to File State’s Reply to Petition for Discretionary Review was subscribed and sworn to before me by Jennifer Stalbaum on this the

c 20th day of January 2015.

Je m er Stalbaum F*IONOA WEDERSTEIN r-n MY COMMISSION EXPIRES Sepnter9, 2018

Notary Public in and for the State of Texas

CERTIFICATE OF CONFERENCE

I certify that I emailed Appellant’s attorney Kevin Fine at kfine@kevinfinelaw.com to ask if he opposed the extension, on January 20, 2015 at :i p.m. Mr. Fine responded that he does not object. t\ /‘\

Jennifer Stali

CERTIFICATE OF SERVICE

I certify that on January 20, 2015, I served the above motion by email to kfine@kevinfinelaw.com, in accordance with the Texas Rules of Appellate Procedure.

)çjnifer ttabaum