COURT OF AI' I'EAI,S NO. 12. 15·0008 1·CR 


TRIAL COURT CAUSE NO. A.2I,464 


JQSII UA I'AUL CALHOUN, 	 , IN TIn: nT" COURT 

AI'!'I-:U . ANT 

VS. , 

THE ST,\ 1'1-: 01­' TEXAS. 

AI'I'.:I.I •• :I-: I Sl\UTII COUNTY, TEXAS 

1'0 1'I1~; IIONORA.I!LE J UDGE OF SA IU COURT: 

COJ\U::S NOW. the APPELLEE. State ofTex:u, by and through her Dbtrict Allomey, 

Nancy J(um:u, and files this J\IOC ion for EAtension of Time to File Appellcc's Brief and in 

upport of the same ....ould show the following: 

I. 

1. 	 Appellee's brief is due 00 or before Oclober 2, 2015. The Appellant's brief is 64 

pages long with II issues. 

2. 	 Appellee requests an additional 60 days from the current due date of October 2. 201 5 

to file its brief with the Court. 

3. 	 Appellee requests an extension of lime for the following reasons: 

a. UndersignWJust finIshed and filed a 30 plus page brief on 

September 21. 20 15. (Sw,~ of UI.< ". Dm",y Ray I ...,.,j:. No. 12· 1)'(X)255 

and No. 12· 14"()(}39). Mr. Lusk was convicted of several counts of 

Aggravated Sc~ual Assault of a c hild and recei"cd sevcral Life sentences. 

ACCEPTED

12-15-00081-CR

TWELFTH COURT OF APPEALS

TYLER, TEXAS

9/30/2015 9:26:56 AM

Pam Estes

CLERK

 FILED IN 12th COURT OF APPEALS TYLER, TEXAS 9/30/2015 9:26:56 AM PAM ESTES Clerk
b. Additionally. undersiJi!ncd counsel is preparing for dod;:cts tile 

w~ek of October 5'~ and 12'h, 2015. an Aggravated Scxual Assault of a Child 

jury trial October 20. 20 15. (State I ', McCan'a: Cause number: CR 15-0 167­

173) and a jury trial docke t thc following ""eck October 27'". 2015. 

c. Additionally, counsel has been assigned to train a ncw 

prosecutor in thc office who has no fclony cxpericncc. 

4, This is the third MOlion for Extension ofTimc rcqucsted by Appell ec. 

5. The undersigned is nOI seeking this extension for the purposes of de lay. 

WHEREFORE. Appellee rcquests thJt thc Coun grant this MOIion and extcnd thc 

deadli ne for filing its bricf for 60 days to December 2. 2015. 

Respectfully. 

-7J'7/~ 

Nancy Rumar 

Assistant District Attorney 

I09W,Corsieana 

Athens. Tellas 7575 1 

Bar, No. 24044654 

Phone: 903·675-6100 

Fall: 903-675-6 196 
CERTI f'l CATF. OF SERVICE 

I. Nancy Rumar, do certify that a true lOdcorrect copy of the fOll'goiog Motion was r"",~ 

to Defendant 's Attoroey,l..c:slie DillOfl, at , S I. ....... 11K '30 day of September, 201~ . 

Signed this the 30 day of September 20 15. 

Nancy Rumar 
STAn: 0.' TEX.t\S I 

COUNTY OF IIENDERSON I 

Befort' rll(', thl' llndersigned nmary, on tllis day, persooally appeared Naocy Runmr. a 

pel'S(ln whose identity is Imown 10 nK'. Arter I administered an oalh 10 hl'r. upon his oalh. she 

:.aid: 

"My name is Nancy Rumar. 1 am capable of making this affidavit The facls stated in 

Ihis affidal'il are wuhin my pen.onal knowledge and are lrue. 

1 am the allomey for the SI31e of Texas vs. Joshua Paul Calhoun ;n Court of Appeals 

Cause No. 12- 1 S-0008 I-CR. I hal'e read thl' fort'going Motion to Extend Time to File 

Appellee's Brief and il is lrue and corm::t " 

Nancy Rumar 

Subscribed and sworn 10 before nit Ihis ~tl" day of Septembcr 20 15. 

~"?P-t- Notary Puhlic -Slal'De ~ a.~