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 THIRD 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 today, June 1, 2015, after two extensions, and I 

have not completed it. 

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

extension: In my second motion, I had asked for an extension until June 10, 

and was granted an extension only until today, June 1. I had another brief and a 

habeas response to write before today, and I accomplished those, but did not 

quite finish this one. On Tuesday of last week, I traveled to the the criminal 

appeals conference in Austin and this weekend I traveled to Mesquite for my 

grandson’s graduation celebration. Today I participated in a motion for new 

trial that began at 1:30 and ended at 5:45, after which I came back to my office 

to get this motion completed and filed. 

3. The State seeks an additional 4 days, until Friday, June 5, 2015. The 

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

prior to the extended deadline. 

4. 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. 

ACCEPTED

06-14-00204-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

6/1/2015 5:54:48 PM

DEBBIE AUTREY

CLERK

 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 6/1/2015 5:54:48 PM DEBBIE AUTREY Clerk
In the past 21 days the undersigned attorney has worked on the following:

A. Appellate brief in aggravated robbery case:

1. Cinque Ross v. State, 06-14-00157-CR (8 volumes, 4 issues) 

filed Monday, May 11, 2015 after one extension.

2. King v.State, 06-14-00166 –CR due June 1, 2015, filed May 21, 

2015 after one extension.

B. Responses to habeas applications:

1. Ex parte Matthew Spratling, due June 1, 2015, filed May 26

C. Protracted motion for new trial, alleging ineffective assistance of 

counsel, State v. Hudgins, 43,645 B, with hearings held on May 22 

and June 1 until 5:45 p.m.

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

following cases in addition to this one:

A. Appellate Briefs:

1. Sibley v. State, 06-15-00009-CR due June 8, 2015.

B. Response to One DNA Motion

1. Bennie Guy v. State, 23,613-B received April 21, 2015.
7. 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

Ebbmob@aol.com

This 1

st day of June, 2015. 

/s/ ZanColsonBrown

Zan Colson Brown 

 Assistant District Attorney