alea-institute/kl3m-data-sample-004-shuffled huggingface dataset:
CASE NO. 12-14-00210-CR

BOBBIE GRUBBS § IN THE COURT OF APPEALS APPELLANT § § VS. § TWELFTH COURT OF APPEALS § THE STATE OF TEXAS, §

APPELLEE § TYLER, TEXAS 

### MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: COMES NOW The State of Texas , Appellee, by and through her District Attorney, Kenneth B. Florence, and files this motion for an extension of 30 days in which to file the Appellee’s Brief. In support of this motion, Appellee shows the court the following:
I. Appellant was convicted in the 273 Judicial District Court of Shelby County, Texas, by a rd jury, of the offense of Capital Murder. The judge assessed punishment at confinement in the Texas Department of Criminal Justice Institutional Division, for Life, without the possibility of Parole.
II. The deadline for filing the Appellee’s Brief was July 3, 2015. That date was the official observance of Independence Day and all county offices were closed. That date has passed, and this motion is accompanied by a motion for leave to file a late motion for extension of time.
III. Appellee’s request for an extension is based upon the following facts: 1. Appellee can get the brief filed within the 30 days requested. 2. This motion is not opposed by defense counsel. ACCEPTED 12-14-00210-CR TWELFTH COURT OF APPEALS

TYLER, TEXAS 7/9/2015 3:06:48 PM CATHY LUSK CLERK3. This motion i s the State’s first motion for an e x tension.

4. The elec ted District Attorney was the only attorney in the office for 4 y ear s, and a new Assistant District Attorney

was just approve d eff

ective June 8, 2015. Wherefor e, Appe llee pray s the court g rant the motion for leave to late file this motion for extension, t his moti on for e x tension, and extend the dea dline for f iling the Appe llee’s B rief to Aug ust 7, 2015.
Respectf ully submitt ed, /s/ Kenneth B . Flore nce KENNET H B . FL ORENCE TBA # 00790698 Shelby County Assistant District Attorney 200 San Aug ustine Street Suite 12 Center, Te x as 75935 (936) 598- 2489 (936) 598- 4106

CERTIFIC ATE OF SERVICE
I here by cer tify that a true and cor

rec t copy of the State’s Motion for Extension of Time to File Appellee’ s Br ief, as rela ted above, was served upon, Ste p h en Shires, Attorney for Appellant,
123 San Aug ustine Street, Center, Texas 75935, by fac simil e (936) 598-3031, on this the 7 day of t h
J uly 2015. /s/ Kenneth B . Flore nce KENNET H B . FL ORENCEAFF I DAVI T

STATE OF TEXAS § § COUNTY OF SHE LBY § “My name is KENNET H B. FL ORENCE; I am over the age of 18 and I am c o mpetent t o make this aff

idavit. I have pe rsonal knowledg e of the following fac ts:
I have rea d the fore g oing motion for extension of time to file Appellee ’s Br ief and the fac ts contained the rein a

re true and within my

persona l knowledg e.”
Fur ther the a ffiant sa

y eth not.

/s/ Kenne t h B. Fl o re n ce

KENN ETH B . F LORENCE