# Jerryl Robinson v. State > Texas Court of Appeals, 3rd District (Austin) · April 20, 2015 URL: https://www.frixlaw.com/law-library/cases/4064225 ## Case - **Court:** Texas Court of Appeals, 3rd District (Austin) - **Decided:** April 20, 2015 - **Precedential status:** Published - **Opinion:** Opinion - **Cited by:** 0 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4064225 ## Opinion text ACCEPTED 03-14-00407-CR 4959695 THIRD COURT OF APPEALS AUSTIN, TEXAS 4/20/2015 4:36:06 PM JEFFREY D. KYLE CLERK NO. 03-14-00407-CR JERRYL ROBINSON § IN THE THIRD FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS V. § DISTRICT 4/20/2015 COURT4:36:06 OF PM JEFFREY D. KYLE THE STATE OF TEXAS § APPEALS OF TEXAS Clerk STATE’S SECOND MOTION TO EXTEND TIME TO FILE BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: Now comes the State of Texas, Appellee in the above styled and numbered cause, and moves for an extension of time of 30 days to file Appellee’s brief, and for good cause would show the following: I. Appellant was convicted by a jury of the offense of Theft > $1,500 < $20,000. The offense was enhanced from a state jail felony to a second-degree felony, and Appellant was sentenced to 15 years confinement on June 11, 2014. Appellant’s brief was originally due November 3, 2014. After two motions for extension were granted by the Court, Appellant filed his brief on February 9, 2015. II. I am handling the appeal for the State in this case.. I was out of the country – performing some manual work while on vacation – from March 21st to March 30th. Upon my return I worked through the Easter weekend on another appellate brief, which I filed shortly before midnight on April 13th in 03-14-00617-CR. On that 1 same day I filed a motion for new trial regarding orders of expunction; the trial court granted the new trial on April 14th. I have also assisted with other appeals and research questions in the office, submitted proposed findings of fact and conclusions of law to the district court, worked on expunctions, and over the past few days I have worked long hours related to a pending petition for mandamus. Because of the foregoing, I have not yet been able to complete a significant amount of work on a response, and respectfully request an extension of 30 days to file the State’s brief in the instant cause. This is the second extension sought by Appellee. III. WHEREFORE, PREMISES CONSIDERED, the State’s counsel respectfully prays for an extension of 30 days, until May 20, 2015, so that an adequate response may be made to Appellant’s brief. This extension is not requested for purposes of delay but so that justice may be done. Respectfully submitted, /s/ Joshua D. Presley Joshua D. Presley SBN: 24088254 preslj@co.comal.tx.us Comal Criminal District Attorney’s Office 150 N. Seguin Avenue, Suite 307 New Braunfels, Texas 78130 Ph: (830) 221-1300 / Fax: (830) 608-2008 2 CERTIFICATE OF SERVICE I, Joshua D. Presley, Assistant District Attorney for the State of Texas, Appellee, hereby certify that a true and correct copy of this State’s Second Motion to Extend Time to File Brief has been delivered to Appellant JERRYL ROBINSON’s attorney in this matter: Marilee H. Brown Marilee@hazelbrownlaw.com Hazel Brown Wright Reneau, PLLC 391 Landa Street New Braunfels, TX 78130 Counsel for Appellant on Appeal By electronically sending it to the above-listed email address through efile.txcourts.gov, this 20th day of April, 2015. /s/ Joshua D. Presley Joshua D. Presley 3 --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4064225. Public record. Not legal advice.