Post Of fice Box 12548, Austin, Texas 7 8 7 1 1 - 2 5 4 8 • ( 5 1 2 ) 4 6 3 - 2 1 0 0 • www.texasattor neygeneral.gov 

October 13, 2015 

Honorable Abel Acosta 

Clerk of the Court of Criminal Appeals 

P.O. Box 12308 

Capitol Station 

Austin, TX 78711 

RE: The State of Texas v. James Alan Jenkins 

Court of Criminal Appeals No. PD-0832-15

 

Dear Mr. Acosta: 

Enclosed please find an original Unopposed Motion for 

Extension of Time to File State’s Brief in the above referenced 

matter. I would ask that you please file this brief in your usual 

manner. 

By copy of this letter, I am forwarding a copy of same to the 

Attorney for Appellee. 

Yours truly, 

/s/ Jon R. Meador 

JON R. MEADOR 

Assistant Attorney General 

Office of the Attorney General 

Enclosure 

cc: George Sechrist, Attorney for Appellee 

Lisa McMinn, State Prosecuting Attorney 

PD-0832-15

COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS

Transmitted 10/13/2015 11:54:30 AM

Accepted 10/13/2015 12:18:49 PM

ABEL ACOSTA

CLERK
CASE NO. PD-0832-15

THE STATE OF TEXAS, § IN THE COURT

APPELLANT §

§ OF CRIMINAL APPEALS

§ 

JAMES ALAN JENKINS, § OF TEXAS

APPELLEE §

STATE’S FIRST UNOPPOSED MOTION FOR EXTENSION OF 

TIME TO FILE STATE’S BRIEF 

COMES NOW, the State of Texas, by and through its Assistant 

District Attorney, Jon R. Meador, and tenders, pursuant to Texas Rules 

of Appellate Procedure 10.5(b) and 38.6(d), this motion for an extension 

of time to file the State’s brief. In support of this motion, the State would 

show:

1. The court below is the Fourteenth District Court of Appeals, 

which in cause number 14-13-00662-CR, reversed the 

judgment of the 359th Judicial District Court of Montgomery 

County Texas in cause no. 12-03-02579-CR, there styled the 

State of Texas v. James Alan Jenkins;

2. This Court granted the State’s petition for discretionary 

review on September 16, 2015; 

3. The State’s brief is due on October 16, 2015;

4. The State is asking for a three-week extension making the 

new deadline November 6, 2015; 

5. This is the first request for an extension;
6. Appellee’s Counsel, George McCall Secrest, Jr. does not 

oppose this motion for an extension of time;

7. The State is requesting this extension so that it might 

adequately address the complex issues involved in this case, 

and it is not requested for the purpose of an improper delay;

8. The State alleges good cause exists for this request to the 

undersigned’s schedule. At the time this Court granted the 

State’s Petition for Discretionary Review (PDR), Counsel was 

in the middle of drafting responses in other cases in federal 

court and has since the granting of the PDR filed five answers 

or responsive pleadings in federal court. Additionally, this 

case involves issues of first impression and are complex. Since 

the court of appeals reversed the trial court’s judgment, the 

State’s position has changed making the drafting of an initial 

brief more time-intensive. Consequently, the undersigned 

attorney is asking for an additional twenty-one days to file his 

brief. 

WHEREFORE, premises considered, the State respectfully 

requests that this Court grant the State’s first motion for extension of 

time for two weeks, until November 6, 2015.

Respectfully submitted,

/s/ Jon R. Meador 

Jon R. Meador

Assistant Attorney General

Office of the Attorney General

300 W. 15th Street

Austin, Texas 78701

(512) 395-4425

State Bar No. 24039051
CERTIFICATE OF SERVICE 

A true copy of the State’s First Motion to Extend Time has been 

mailed to Counsel for Appellant, George McCall Secrest, Jr., Bennett & 

Secrest, LLP, 808 Travis, 24th Floor, Houston, Texas 77002-4177, and 

the State Prosecuting Attorney, Lisa McMinn, P.O. Box 13046, Capitol 

Station, Austin, Texas 78711-3046.

/s/ Jon R. Meador

JON R. MEADOR

Assistant Attorney General