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NO. 03-14-00371-CR

JIM JACK THOMPSON § IN THE COURT OF APPEALS 

§

v. § THIRD DISTRICT 

§

STATE OF TEXAS § AUSTIN, TEXAS 

 SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF 

NOW COMES THE STATE OF TEXAS, Appellee, by and through her 

Assistant District Attorney, John C. Prezas, and moves the Court, pursuant to Texas 

Rule of Appellate Procedure 38.6(d), to extend the deadline for filing the State’s brief. 

In support of its motion, the State would show the Court the following: 

1. The State’s Brief in this case is due on July 14, 2015. The State has requested, and 

this Court has granted, one previous extension of time. 

2. Appellant’s brief was filed in this Court on April 14, 2015. 

3. Mr. Prezas recently filed the State’s proposed findings of fact and conclusions of 

law in the following habeas corpus proceedings: Ex Parte Santos Loa 86-252-KC; 

Ex Parte Ramon Cavazos Jr. 07-1628-K277A; Ex Parte Troy Dale Mansfield 92-

435-K277A; Ex Parte Rolando Bacon Lopez, 10-1053-K368A; Ex Parte Robert 

Jesse Padilla, 06-937-K368A; Ex Parte Robert Jesse Padilla, 06-921-K368A; Ex 

Parte Daniel Robert Lock, 94-085-K277A; Ex Parte Daniel Robert Lock 97-780-

ACCEPTED

03-14-00371-CR

6045947

THIRD COURT OF APPEALS

AUSTIN, TEXAS

7/13/2015 4:44:17 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 7/13/2015 4:44:17 PM JEFFREY D. KYLE Clerk
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K277A.

4. Mr. Prezas has recently filed answers in the following habeas corpus proceedings: 

Ex Parte William Johnson 88-405-KF, Ex Parte Joseph Paul Mayzone 93-070-

K277A,Ex Parte Steven M. Ruiz 12-1097-K26A, Ex Parte Victor Manuel Soto 13-

1581-K26A, Ex Parte Edwin Gus Schneider 10-960-K26A,and Ex Parte Timothy 

Jerrold Kipp 13-0658-K277A and 13-0622-K277A.

5. Mr. Prezas is currently meeting with attorneys to gather affidavits in anticipation of 

filing proposed findings of fact and conclusions of law in the habeas proceedings of 

Ex Parte Wendi Ann Tillman 06-1062-K368A.

6. Mr. Prezas filed a State’s brief on May 21, 2015, in response to the Court of 

Criminal Appeals granting the State’s petition for discretionary review in John Alan 

Wachtendorf, PD-0280-15. Mr. Prezas submitted a State’s Motion to Dismiss in 

State vs. Gregory Michael Klapesky 03-15-00244-CR on June 5, 2015.

7. Currently, Mr. Prezas is evaluating a request for DNA testing under Chapter 64 in 

03-1063-K277 State vs. Gregory Michael Klapesky.

8. For the foregoing reasons, The State respectfully requests that the deadline for 

filing its brief in the above stated cause be extended for an additional sixty two

(62) days from the current due date of July 14, 2015, to September 14, 2015.
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WHEREFORE, PREMISES CONSIDERED, the State of Texas respectfully 

requests that this Court grant its motion for an extension of time and extend the State’s 

deadline to file its brief to September 14, 2015.

Respectfully submitted,

Jana Duty

District Attorney

Williamson County, Texas

/s/ John C. Prezas

John C. Prezas

Assistant District Attorney

State Bar Number 24041722

405 Martin Luther King #1

Georgetown, Texas 78626

(512) 943-1248

(512) 943-1255 (fax)

jprezas@wilco.org

Certificate of Service

This is to certify that on July 13, 2015, a copy of the foregoing motion has been 

sent to Appellant’s attorney of record, Ray Bass, 120 W. 8th street, Georgetown, TX 

78626, by eservice at ray@raybass.com.

/s/ John C. Prezas 

John C. Prezas