ACCEPTED03-15-00153-CR8268787THIRD COURT OF APPEALSAUSTIN, TEXAS12/16/2015 3:26:16 PMJEFFREY D. KYLECLERKNo.03-15-00153-CRINTHECOURTOFAPPEALSFORTHETHIRDDISTRICTOFTEXAS.THESTATEOFTEXAS,Appellantv.FRANCESANITAROBINSON,AppelleeOnAppealfromthe207thJudicialDistrictCourtofComalCounty,TexasCauseNo.CR2013-267HonorableBruceBoyer,DistrictJudgePresidingMOTIONTOEXTENDTIMETOFILEAPELLEE'SBRIEFSullivan&Associates,PLLCByCharlesSullivanTexasBarNo.24049421308CampbellDriveCanyonLake,TX78133(830)899-3259Phone(210)579-6448Faxcsullivan@lawcullivan.comAttorneyforAppelleeRobinson

### MOTION TO EXTEND TIME TO FILE APPELLEE'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: Now comes Francis Anita Robinson, Appellee in the above styled and numbered

cause, and moves this Court to grant an extension of time to file appellant's brief, pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good cause shows the following: 1. This case is on appeal from the 207th Judicial District of Comal County, Texas. 2. The case below was styled the STATE OF TEXAS vs. FRANCES ANITA ROBINSON, and numbered CR2013-267. 3. Appellant State is appealing Motion to Supress Evidence granted by the trial court on February 18,2015. 4. The appellate filed their brief on October 16, 2015. 5. Appellee requests an extension of time of30 days from the current due date, i.e., December 21, 2015. 6. Appelle has previously requested one extension on November 19, 2015 which was granted. 7. Defendant is currently free on bond. WHEREFORE, 

### PREMISES CONSIDERED, 

### Appellee prays that this Court grant this Motion To Extend Time to File Appellee's Brief, and for such other and further

No. 03-15-00153-CR, State v Robinson, Motion to Extend Time to File Appellee's Briefrelief as the Court may deem appropriate.

STATE OF TEXAS COUNTY OF COMAL Respectfully submitted,

# Char**llivan** Texas Bar No. 24049421 Sullivan & Associates, PLLC 308 Campbell Drive Canyon Lake, TX 78133 (830) 899-3259 Phone (21 0) 579-6448 Fax



### § § §

AFFIDAVIT BEFORE ME, the undersigned authority, on this day personally appeared Charles Sullivan, who after being duly sworn stated: "I am the attorney for the appellant in the above numbered and entitled

cause. I have read the foregoing Motion To Extend Time to File Appellant's Brief and swear that all of the allegations of fact contained therein are true and correct."

No

. 03-15-00153-CR, State v Robinson, Motion to Extend Time to File Appellee's Brief

### SUBSCRIBED AND SWORN TO BEFORE ME on December 16, 2015, to certify which witness my hand and seal of office.



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Certificate of Service I, Charles Sullivan, attorney for Frances Anita Robinson, Appellee, hereby certify that a true and correct copy of this Motion has been delivered to Appellant via State's attorney of record in this matter: Jennifer Tharp, Criminal District Attorney Daniel Palmitier, Assistant District Attorney 150 N. Seguin Avenue, Suite #307 New Braunfels, Texas 78130 (830) 221-1300 Fax (830) 608-2008 E-mail: preslj @co.comal. tx. us Attorneys for State By electronically sending it through efile.txcourts.gov service, this l6 1 h day of December, 2015.

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# f}J~

Charles Sullivan

No. 03-15

- 00153

- CR, State v Robinson, Motion to Extend Time to File Appellee's Brief