Thornburgh, Robert Jr.

Opinion

PD-0230-15

COURT OF CRIMINAL APPEALS AUSTIN, TEXAS

Transmitted 3/16/2015 1:41:36 PM Accepted 3/18/2015 3:11:21 PM ABEL ACOSTA

CAUSE NO. PD-0230-15 CLERK COURT OF APPEALS CAUSE NO. 11-12-00328-CR IN THE COURT OF CRIMINAL APPEALS

ROBERT THORNBURGH, JR. )( ON APPELLANT’S APPELLANT/PETITIONER )( )( PETITION FOR DISCRETIONARY V. )( REVIEW )(

THE STATE OF TEXAS )( FROM THE ELEVENTH APPELLEE )( COURT OF APPEALS

MOTION FOR EXTENSION OF TIME TO FILE RESPONSE NOW COMES the State of Texas, Appellee in the above-entitled and numbered cause, and in support of this its Motion for Extension of Time to File Response would respectfully show the Court as follows:

Appellant was convicted of two counts of Sexual Assault of a Child, in the 35th Judicial District Court of Brown County, Texas, in Cause No. CR21718, styled, The State of Texas vs. Robert Thornburgh, Jr. Appellant was sentenced to two life terms in the Institutional Division - Texas Department of Criminal Justice on December 15, 2011.

The Eleventh Court of Appeals affirmed Appellant’s conviction on February 5, 2015. Appellant filed a Petition for Discretionary Review with this Court on March 2, 2015.

March 18, 2015

The State’s response is due on March 17, 2015. The number of extensions previously requested is: NONE.

Due to time constraints created as a result of: preparing for trial, drafting subpoenas, and witness meetings on cases set on the Mills County trial docket for February 23, 2015; first chair on jury trial in the State of Texas vs. Hesiquio Cantu, Mills County Case No. 2981 on February 24, 2015; being involved in the preparation of cases and drafting subpoenas for the Motion to Revoke and Motion to Adjudicate Docket on March 9, 2015 (37 cases); Court Docket on March 9, 2015; Court Docket on March 10, 2015; the State requests an additional thirty (30) days for the preparation of its brief. The request is made not for the purpose of delay but that justice may be done.

Respectfully submitted,

/S/ Elisha Bird

ELISHA BIRD

Assistant District Attorney State Bar No. 24060339

200 S. Broadway, Brownwood, TX 76801 Tel: 325-646-0444 Fax: 325-643-4053

CERTIFICATE OF SERVICE

The undersigned certifies that on the 16th day of March, 2015, a true and correct copy of the foregoing Motion was delivered by fax to the office of Erika Copeland, Attorney at Law (512) 219-8930 and by email to Lisa McMinn, State Prosecuting Attorney at information@spa.texas.gov.

/S/ Elisha Bird

ELISHA BIRD

CERTIFICATE OF COMPLIANCE This document complies with the typeface requirements of Tex. R. App. P.

9.4(e) because it has been prepared in a conventional typeface no smaller than 14- point for text and 12-point for footnotes. This document also complies with the word-count limitations of Tex. R. App. P. 9.4(i), if applicable, because it contains 454 words, excluding any parts exempted by Tex. R. App. P. 9.4(i)(1).

/S/ Elisha Bird

ELISHA BIRD