NO. 06-14-00079-CR

JUSTIN SANDERS * ON APPEAL FROM THE 

 Appellant *

 * 102ND JUDICIAL DISTRICT 

VS. * 

STATE OF TEXAS * COURT OF BOWIE COUNTY 

 Appellee * TEXAS 

MOTION TO EXTEND TIME FOR FILING STATE’S BRIEF

TO THE HONORABLE JUSTICES OF SAID COURT: 

 COMES NOW the State of Texas by and through her below named Assistant Criminal 

District Attorney and pursuant to the Texas Rules of Appellate Procedure and hereby requests a thirty 

(30) day extension of the time period for the filing of the State’s Brief and in support of the same 

would show the Court as follows: 

I.

 1. This case is pending from the 102nd Judicial District of Bowie County, Texas. The date of 

the judgment is April 2, 2014. 

 2. The case is styled State of Texas v. JUSTIN SANDERS, Cause Number 13F-1051-102. 

 3. Appellant was convicted of the offenses of MURDER.

 4. Punishment was assessed at imprisonment for thirty (30) years in the Institutional Division 

of the Texas Department of Criminal Justice and a $5,000 fine. 

 5. Appellant’s Brief was filed on December 19, 2014, making the State’s Brief originally due 

on or about January 20, 2015. 

 6. The State has not previously requested an extension of time for filing the State’s Brief. 

 7. The Brief was not timely prepared in this matter due to the holiday season and the press of 

the business. Said business includes, but is not limited to, the following since Appellant’s brief was 

filed: 

ACCEPTED

06-14-00079-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

1/20/2015 12:25:33 PM

DEBBIE AUTREY

CLERK

 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 1/20/2015 12:25:33 PM DEBBIE AUTREY Clerk
 Preparation of the State’s Brief in Leavelle Franklin v. State of Texas in cause 

numbers 06-14-00046-CR and 06-14-00047-CR, which was timely filed on January 5, 

2015. 

 Prepare for and attend docket for the 202nd District court on January 5, 2015. 

 Prepare for and attend docket for the 102nd District Court on January 8, 2015.

 Preparation of the State’s Brief in Steven Wayne Morgan v. State of Texas in cause 

number 06-14-00119-CR, which was timely filed on January 16, 2015. 

 Preparation of the following cases set for trial on January 16, 2015 by Judge Bobby 

Lockhart of the 102nd District Court: 14F-0270-102, Jacob Howard – Aggravated Robbery; 

14F-0303-102, Jacob Howard – Possession of a Controlled Substance (1-4 grams). Mr. 

Howard entered a plea of guilty to both offenses on January 8, 2015 and was sentenced to 

thirty (30) years in the Institutional Division of the Texas Department of Criminal Justice

on the charge of Aggravated Robbery and ten (10) years in the Institutional Division of the 

Texas Department of Criminal Justice on the charge on Possession of a Controlled 

Substance (1-4 grams). 

 Prepare for and attend docket for the 202nd District Court on January 16, 2015.

 Preparation of the following cases set for trial on February 7, 2015 by Judge Bobby 

Lockhart of the 102nd District Court: 13F-0312-102 – Richard Turner, Burglary of a 

Habitation with Intent to Commit Aggravated Assault; 13F-0329-102 – Richard Turner, 

Aggravated Assault with a Deadly Weapon. 

 Preparation of the State’s Brief in Shawn Smith v. State of Texas, which is due on 

February 9, 2015. 

 Preparation of the following cases set for trial on February 16, 2015 by Judge Bobby

Lockhart of the 102nd District Court: 14F-0133-102, Richard Darby – Aggravated Robbery; 

14F-0179-102, Richard Darby – Aggravated Robbery; 14F-0252-102, Richard Darby –

Aggravated Robbery; 14F-0521-102, Richard Darby – Aggravated Sexual Assault; 14F0522-102, Richard Darby – Aggravated Sexual Assault; 14F-0098-102, Richard Darby –
Evading Arrest of Detention in a Motor Vehicle; and 14F-0180-102, Richard Darby – Theft 

($1,500 – 20,000). 

II.

The State’s attorney has been diligent in pursuing this appeal and is not seeking this 

extension for the purpose of delay. 

PRAYER

WHEREFORE, on the bases of Rule 73 of the Texas Rules of Appellate Procedure, the State 

respectfully requests this Court to grant the Motion for Extension of Time for the filing of the State’s 

Brief.

Respectfully submitted,

/s/

SAMANTHA J. OGLESBY

Texas Bar No. 24070362

601 Main Street

Texarkana, TX 75501

ATTORNEY FOR THE STATE

 Samantha J. Oglesby
CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and foregoing Motion to Extend 

Time for Filing State’s Brief was forwarded to Mr. Craig Henry, counsel for Appellant, on this the 

20th day of January, 2015. 

/s/

SAMANTHA J. OGLESBY

 Samantha J. Oglesby