CAUSE NO. 06

- 14

- 00 115- 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

, 201 5, 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 fo llowing:

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

CLERK3. Ex parte Terry Miller 30,600

- A

- H

- 8

, WR 37,856

- 1 1 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 pre vious extension s ha ve 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 20 th day of March, 201 5

. /s/ 

## ZanColsonBrown

Zan Colson Brown A ssistant Criminal District Attorney