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No. 03-14-00155-CR

IN THE

COURT OF APPEALS

THIRD DISTRICT OF TEXAS

AUSTIN, TEXAS

JERON DEANGELO NEAL § APPELLANT

VS. §

THE STATE OF TEXAS § APPELLEE

APPEAL FROM THE 390TH JUDICIAL DISTRICT COURT

TRAVIS COUNTY, TEXAS

CAUSE NO. D1-DC-12-205121

STATE'S SECOND MOTION FOR EXTENSION OF TIME

TO THE HONORABLE COURT OF APPEALS:

The State of Texas respectfully moves for an extension of the deadline for filing

the State’s brief and, in accordance with Texas Rules of Appellate Procedure 38.6 and

10.5(b), advises the Court as follows:

(a) Following his convictions for Aggravated Robbery with a Deadly Weapon,

the appellant filed his notice of appeal in the above cause on March 7, 2014.

Appellant’s counsel filed a brief on January 15, 2015.

ACCEPTED

03-14-00155-CR

4557737

THIRD COURT OF APPEALS

AUSTIN, TEXAS

3/19/2015 9:38:27 AM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 3/19/2015 9:38:27 AM JEFFREY D. KYLE Clerk
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(b) The State’s brief is currently due on March 19, 2015.

(c) This request is that the deadline for filing the State’s brief be extended by

30 days.

(d) The number of previous extensions of time granted for submission of the

State’s brief is: one.

(e) The State relies upon the following facts to reasonably explain the need

for an extension of the deadline:

1. During the period since the appellant’s brief was filed, the undersigned

attorney has completed and filed an original brief in two other pending

appellate cases (i.e., In re Robert Lee Brown, No. 03-14-00681-CR; and

Shriya Patel v. State of Texas, No. 03-14-00238-CR). The undersigned

attorney has also completed and filed a supplemental brief in another

pending appellate case (i.e., In the Matter of J.M., No. 03-14-00027-CV).

The undersigned attorney is responsible for preparing the State’s brief in

another pending appellate case, (i.e., Charles Anthony Malouff, Jr. v. State of

Texas, No. 03-13-00723-CR).

2. In addition, the undersigned attorney, as the director of the Appellate

Division of the Travis County District Attorney’s Office, has been required,

during the pendency of the instant appeal, to spend a considerable amount of
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time working on a variety of other legal matters and administrative issues.

3. This request is not made for the purpose of delay, but to ensure that the

Court has a proper State’s brief to aid in the just disposition of the above

cause.

WHEREFORE, the State of Texas respectfully requests that the deadline for

filing the State’s brief be extended to April 20, 2015.

Respectfully submitted,

ROSEMARY LEHMBERG

District Attorney

Travis County, Texas

/s/ M. Scott Taliaferro

M. Scott Taliaferro

Assistant District Attorney

State Bar No. 00785584

P.O. Box 1748

Austin, Texas 78767

(512) 854-9400

Fax No. (512) 854-4810

Scott.Taliaferro@traviscountytx.gov

AppellateTCDA@traviscountytx.gov
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CERTIFICATE OF COMPLIANCE

Pursuant to Texas Rule of Appellate Procedure 9.4(i), I hereby certify, based

upon the computer program used to generate this motion, that this motion contains

335 words, excluding words contained in those parts of the motion that Rule 9.4(i)

exempts from inclusion in the word count. I certify, further, that this motion is

printed in a conventional, 14-point typeface.

/s/ M. Scott Taliaferro

M. Scott Taliaferro

Assistant District Attorney

CERTIFICATE OF SERVICE

I hereby certify that, on the 19th day of March, 2015, a true and correct copy

of this motion was served, by U.S. mail, electronic mail, facsimile, or electronically

through the electronic filing manager, to the Appellant’s attorney, John S. Butler,

Attorney at Law, 700 Lavaca Street, Suite 1400, Austin, Texas 78701.

/s/ M. Scott Taliaferro

M. Scott Taliaferro

Assistant District Attorney