CAUSE NO. 06-14-00115-CR

CORDERO BROWN § 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

 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, March 23, 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, April 22, 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, 

appeals from justice courts, and applications for habeas corpus. 

In the past 30 days the undersigned attorney has completed the following: 

A. Appellate Briefs: 

1. March 4, 2015, Kelly v. State, PD 0702-13

B. Responses to Writ Applications: 

1. Ex parte Larry Means 42561-B-H-? 

WR-16,525-07, February 25, 2015 

2. Ex parte Ryan Woods, 39,923B H 1, WR 37,856-10, March 

13, 2015 

ACCEPTED

06-14-00115-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

3/20/2015 1:44:03 PM

DEBBIE AUTREY

CLERK

 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 3/20/2015 1:44:03 PM DEBBIE AUTREY Clerk
3. Ex parte Terry Miller 30,600-A-H-8, WR 37,856-11 March 

16, 2015.

C. PDR’s reviewed:

1. Palmer v. State, 6-13-00265-CR, February 12, 2015. 

2. Thomas v. State, 6-14-00002-CR, February 13, 2015.

In the next 30 days the undersigned attorney must respond to the following

in addition to this brief:

A. Appellate Briefs due:

1. Ross v. State, 06-14-00157-CR April 10, 2015

B. Due dates for responses, if any, to PDR, after no extensions

1. Saddler v. State, 06-14-00175-CR, requested due date: 

March 23, 2015.

C. Habeas responses due:

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

30, 2015

2. Ex parte Moises Rentaria 38,802-A-H-1 March 31, 2015

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

2015. 

4. Ex parte James Pierce 37,630 A-H-3 March 31, 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 an appellate brief, 

and four habeas responses, as shown above.
b. I have also read the brief and the 10-volume record in this case, but I have 

not finished writing the brief.

c. No previous extensions have been requested by the State in this case.

d. 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 Criminal 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 appellant by e-service addressed to Mr. Lew Dunn at 

dunn@texramp.com. 

This 20th day of March, 2015. 

/s/ ZanColsonBrown

Zan Colson Brown 

 Assistant Criminal District Attorney