CAUSE NO. 06

- 14

- 00 204- 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 SECOND 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 du e Monday

, May 11

, 2015

, after one extension and I have not completed it due to other matters with more pressing deadlines.

2. The State seeks an additional 30 days from May 11, until Wednesday

, June 10

, 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 dir ect appeals and applications for habeas corpus, bond forfeitures and traffic citation appeals

. In the past 30 days the undersigned attorney has worked on the fo llowing:

A. Appellate brief in aggravated robbery case:

1. Cordero Brown v. State, 06

- 14 -00115- CR

, (10 volumes; 5 issues) due April 22, 2015 after one extension

. A Cinque Ross v. State, 06

- 14 -00157- CR (8 volumes, 4 issues) due Monday, May 11, 2015 after one extension. ACCEPTED 06-14-00204-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 5/8/2015 5:00:58 PM DEBBIE AUTREY

CLERKB. Responses to habeas a pplications: 1

. Ex parte Montalbano, 41,041

- B

- H

- 1 d ue April 25 , 2015. 2

. Ex parte Young, 42, 697

- B

- H

- 2, due April 28, 2015. 3

. Ex parte Wyatt, 40, 788

- A

- H

- 2?, due April 28, 2015. 4

. Ex parte Player, 42,164

- A

- H

- 1

, due April 29, 2015 5

. Ex parte Freeman , 42,132

- B

- H

- 2, due April 29, 2015. 6. Ex parte Spratling

, 26,307

- B

- H

- 1 d ue May 1 0 , 2015.

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

. King v.State, 06

- 14

- 00 166

– CR due June 1 , 2015. 2. Sibley v. State

, 06

- 1 5

- 00009

- CR due June 8 , 2015

.

B. R esponse to One DNA Motion

1. Bennie Guy v. State , 23,613

- B received April 21, 2015.

7. Appellant relies on the following facts as good cause for the requested extension:

A

. During the past 30 days, the undersigned has submitted nine habeas
responses, as shown above , and has worked on the Brown brief , which is now 95 percent complete

. In addition, I have processed numerous traffic court appeals a nd bond forfeiture cases.

B . I will be attending the Robert Dawson Co nference on Crimi nal Appeals in A ustin on May 27

- 29. One previous extension has been requested by the State in this case.C. 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 756 06 Ebbmob @ aol.com

This 8 th day of May , 201 5

.

/s/ 

## ZanColsonBrown
Zan Colson Brown Assistant District Attorney