Court of Civil Appeals of Texas, 2015

Ronjee Middleton v. State

Court of Civil Appeals of Texas · Decided April 8, 2015

Opinion

ACCEPTED 04-14-00678-CR FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 4/8/2015 11:33:34 AM KEITH HOTTLE CLERK NO. 04-14-00678-CR RONJEE MIDDLETON § IN THE FOURTH DISTRICT § § VS. § COURT OF APPEALS § § STATE OF TEXAS § SAN ANTONIO, TEXAS

MOTION FOR EXTENSION OF TIME TO FILE STATE’S BRIEF TO THE HONORABLE JUDGES OF THE FOURT COURT OF APPEALS: NOW COMES Nicholas “Nico” LaHood, Criminal District Attorney of Bexar County and Counsel for the State of Texas, and files this Motion asking that the Court extend the time for filing the State’s brief.

Appellant was found guilty of aggravated assault with a deadly weapon. On September 19, 2014, he was sentenced to 27 years in the Texas Department of Criminal Justice, Institutional Division. Appellant filed a timely notice of appeal on September 19, 2014. The clerk’s record was filed on November 6, 2014 and a supplemental clerk’s record was filed on December 19, 2014. The reporter’s record was filed on November 18, 2014 and a supplemental reporter’s record was filed on February 5, 2015. Appellant filed his brief on March 9, 2015. The State’s brief was due April 8, 2015. This is the State’s first motion requesting an extension of time and the State requests a 30 day extension to May 7, 2015.

1 of 3 This extension is not sought for the purpose of delaying this appeal. The State requests an extension for the following reasons: 1) Counsel would like more time to thoroughly read the record in this case, as well as to research and write the State’s brief.

2) Counsel has recently been transferred to the Appellate Division of the District Attorney’s Office.

3) Due to the restructuring of the District Attorney’s Office, counsel has been assisting the trial division with intake and presentment of cases to the grand jury.

4) Counsel recently filed the following brief in the Fourth Court of Appeals: a. In the Interest of D.M., Children, 04-14-00858-CV.

Therefore, counsel respectfully asks the Court to grant this extension of time to file the State’s brief in this case.

WHEREFORE, PREMISES CONSIDERED, Counsel for the State prays that the Court grant an extension of time to May 7, 2015 for filing the State’s brief.

Respectfully submitted, Nicholas “Nico” LaHood Criminal District Attorney Bexar County, Texas /s/ Jennifer D. Rossmeier ____________________ Jennifer D. Rossmeier State Bar No. 24079247 Assistant Criminal District Attorney W. Nueva Street San Antonio, Texas 78205-3030 Phone: (210) 335-2734 Fax: (210) 335-2436 Email: [email protected]

2 of 3 CERTIFICATE OF SERVICE I, Jennifer D. Rossmeier, Assistant District Attorney, Bexar County, Texas, certify that a copy of the foregoing motion was delivered via electronic service to Michael D. Robbins, on April 8, 2015.

/s/ Jennifer D. Rossmeier

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