CAUSE NO. 06-14-00157-CR

CINQUE ROSS § IN THE COURT OF APPEALS 

§ 

VS. §IN AND FOR THE SIXTH DISTRICT 

§ 

THE STATE OF TEXAS § OF THE STATE OF TEXAS

STATE'S FIRST MOTION TO EXTEND TIME 

FOR FILING STATE’S BRIEF

TO THE HONORABLE JUDGE OF SAID COURT: 

 THE STATE OF TEXAS, by and through the undersigned Assistant District 

Attorney, respectfully moves the Court to extend the time for filing of the 

Appellee’s Brief in accordance with Rule 10.5 of the Texas Rules of Appellate 

Procedure. In support of its motion, the State respectfully offers the following: 

1. The Appellee’s brief is due today, April 10, 2015, and I have not completed it 

due to other matters with more pressing deadlines. 

2. The State seeks an additional 31 days, until Monday, May 11, 2015. The 

undersigned will, nonetheless, attempt to complete and file the State’s brief 

prior to the extended deadline. 

3. The undersigned attorney is responsible for all post-conviction prosecution for 

the Gregg County Criminal District Attorney’s Office, including direct appeals 

and applications for habeas corpus, bond forfeitures and traffic citation appeals. 

In the past 30 days the undersigned attorney has worked on the following: 

A. Appellate Brief 

 

1. Cordero Brown v. State, 06-14-00115-CR, (10 volumes; 5 

issues) April 22, 2015 after one extension . 

B. Responses to Six Writ Applications: 

ACCEPTED

06-14-00157-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

4/10/2015 11:35:12 AM

DEBBIE AUTREY

CLERK

 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 4/10/2015 11:35:12 AM DEBBIE AUTREY Clerk
1. Ex parte Ryan Woods, 39,923B H 1, WR 37,856-10, March 13, 

2015

2. Ex parte Terry Miller 30,600-A-H-8, WR 37,856-11 March 16, 

2015.

3. Ex parte Laderick Morgan 33,311-B-H-1 March 31, 2015.

4. Ex parte Moises Renteria 38,802-A-H-1 April 1, 2015.

5. Ex parte James Pierce 37630-A.H-3 April 1, 2015.

6. Ex parte Cline 16,318-A-H-12?, WR-16.199-02, March 30, 2015

C. PDR’s reviewed:

1. Saddler v. State, 6-14-00016-CR, March 23, 2015. 

2. Pruitt v. State, 6-14-00216-CR, March 30, 2015.

4. In the next 30 days the undersigned attorney has briefing deadlines in the 

following cases in addition to this one:

A. Brown v. State, 06-14-00115-CR;

(10 volumes; 5 issues) April 22, 2015 after one extension

B. Nelson v. State, 06-14-00204-CR, April 20, 2015

5. Appellant relies on the following facts as good cause for the requested 

extension:

A. During the past 30 days, the undersigned has submitted seven habeas 

responses, as shown above, and has worked on the Brown brief. In 

addition, I have processed numerous traffic court appeals and bond 

forfeiture cases. 

B. No previous extensions have been requested by the State in this case.
C. This extension is not requested for purposes of delay, but so that 

justice may be done.

Respectfully submitted,

/s/Zan Colson Brown

Zan Colson Brown

Texas Bar No. 03205900

Assistant District Attorney

101 East Methvin St., Suite 333

Longview, TX 75601

Telephone: (903) 236–8440

Facsimile: (903) 236–3701

E-mail: zan.brown@co.gregg.tx.us

CERTIFICATE OF SERVICE

I certify that a true and correct copy of the above and foregoing has been 

forwarded to all counsel of record by electronic transmission to:

Mr. Lew Dunn

P.O. Box. 2226

Longview, Texas 75606

Dunn@texramp.net

This 10th day of April, 2015. 

/s/ ZanColsonBrown

Zan Colson Brown 

 Assistant District Attorney