. THE STATE OF TEXAS, Appellant 

v. 

FRANCES ANITA ROBINSON, Appellee 

On Appeal from the 207th Judicial District Court of Comal County, Texas 

Cause No. CR2013-267 

Honorable Bruce Boyer, District Judge Presiding 

MOTION TO EXTEND TIME TO FILE APELLEE'S BRIEF 

Sullivan & Associates, PLLC 

By 

Charles Sullivan 

Texas Bar No. 24049421 

308 Campbell Drive 

Canyon Lake, TX 78133 

(830) 899-3259 Phone (210) 579-6448 Fax 

csullivan@lawcullivan.com 

Attorney for Appellee Robinson 
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 Brief 
relief as the Court may deem appropriate. 

STATE OF TEXAS 

COUNTY OF COMAL 

Respectfully submitted, 

Texas 

Char Bar No. llivan 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. 

-

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 l61h day of 

December, 2015. . f}J~ 

Charles Sullivan 

No. 03-15-00153-CR, State v Robinson, Motion to Extend Time to File Appellee's Brief