CAUSE NO. 06-14-00204-CR

CLIFFORD BERNARD NELSON § IN THE COURT OF APPEALS 

§ 

VS. § 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

 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 Monday, April 20, 2015, and I have not completed 

it due to other matters with more pressing deadlines. 

2. The State seeks an additional 30 days, until Wednesday, May 20, 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 in aggravated robbery case: 

 

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

issues) due April 22, 2015 after one extension . 

B. Responses to habeas applications: 

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

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

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

ACCEPTED

06-14-00204-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

4/17/2015 4:34:55 PM

DEBBIE AUTREY

CLERK

 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 4/17/2015 4:34:55 PM DEBBIE AUTREY Clerk
4. 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. Appellate Briefs:

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

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

2. Ross v. State, 06-14-00157-CR due May 11, 2015. 

B. Responses to 5 habeas applications 

1. Ex parte Montalbano, 41,041-B-H-1 due April 25, 2015.

2. Ex parte Young, 42, 697-B-H-2, due April 28, 2015.

3. Ex parte Wyatt, 40, 788-A-H-2?, due April 28, 2015.

4. Ex parte Player, 42,164-A-H-1, due April 29, 2015

5. Ex parte Freeman, 42,132-B-H-2, due April 29, 2015.

4. 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, which is 

now 95 percent complete. 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. Ebb Mobley

P.O. Box. 2309

Longview, Texas 75606

Ebb Mob@aol.com

This 17th day of April, 2015. 

/s/ ZanColsonBrown

Zan Colson Brown 

 Assistant District Attorney