Sergio Fonza-Carey v. State

Opinion

ACCEPTED

06-15-00201-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS 7/6/2016 10:52:07 AM

DEBBIE AUTREY

CLERK

CAUSE NO. 06-15-00201-CR

SERGIO RASHAD FONZA-CAREY § IN THE COURT OF APPEALS FILED IN

6th COURT OF APPEALS

§ TEXARKANA, TEXAS VS. § FOR THE SIXTH 7/6/2016 DISTRICT

10:52:07 AM

§ DEBBIE AUTREY THE STATE OF TEXAS § OF THE STATEClerkOF TEXAS

STATE'S FIRST MOTION TO EXTEND TIME FOR FILING STATE’S BRIEF

THE STATE OF TEXAS, by and through the undersigned Assistant District Attorney, respectfully moves the Court to extend the time for filing of the Appellee’s Brief in accordance with Rule 10.5 of the Texas Rules of Appellate Procedure. In support of its motion, the State respectfully offers the following:

1. The Appellee’s brief is due July 7, 2016, and I have not completed it. This is the State’s first motion to extend time in this case.

2. The State seeks an additional 32 days, until August 8, 2016. The undersigned will nevertheless attempt to complete and file the State’s brief prior to the extended deadline.

3. The undersigned attorney is responsible for all post-conviction prosecution for the Gregg County Criminal District Attorney’s Office, including direct appeals and applications for habeas corpus, bond forfeitures and traffic citation appeals.

In the past 30 days the undersigned attorney has worked on the following:

A. Appellate briefs:

Garcia v. State 06-15-00187, filed on June 21 State v. Reel 06-15-00230-CR filed on June 28

4. In the next thirty days, Appellee also has one more brief due in this court:

State v. Strube, 06-15-00185-CR due July 21.

5. In addition, the undersigned attorney was out of town from June 22-24, and will be out of state from July 12-14.

6. Appellant relies on the above facts as good cause for the requested extension.

7. This extension is not requested for purposes of delay, but so that justice may be done.

Respectfully submitted, /s/Zan Colson Brown Zan Colson Brown Texas Bar No. 03205900 Assistant District Attorney 101 East Methvin St., Suite 333 Longview, TX 75601 Telephone: (903) 236–8440 Facsimile: (903) 236–3701 E-mail: zan.brown@co.gregg.tx.us

CERTIFICATE OF SERVICE

I certify that a true and correct copy of the above and foregoing has been

forwarded to all counsel of record through Texas e-file.com

Mr. Clement Dunn 140 E, Tyler Street, Suite 240 Longview, Texas 75601 clementdunn@aol.com

This 6th day of July, 2016.

/s/ ZanColsonBrown Zan Colson Brown Assistant District Attorney