ACCEPTED 12-15-00039-CR TWELFTH COURT OF APPEALS TYLER, TEXAS 11/6/2015 9:13:10 PM Pam Estes CLERK Cause No. 12-15-00039-CR FILED IN 12th COURT OF APPEALS TYLER, TEXAS In the Court of Appeals for the 11/6/2015 9:13:10 PM Twelfth Judicial District at Tyler, Texas PAM ESTES Clerk

Taurus Jenkins, Appellant v. State of Texas, Appellee

On Appeal from Cause No. 2014-0191 in the 159th Judicial District Court of Angelina County, Texas

State’s Motion for Extension (Unopposed)

To the Honorable Justices of this Court: Appellee, State of Texas, moves for a 30-day extension of time to file its brief.

I.

Undre the Texas Rules of Appellate Procedure, the general deadline to file an appellee’s brief is 30 days after the date the appellant’s brief was filed. Tex. R.

App. P.38.6(b). Appellant’s Brief was filed on October 7, 2015, giving the State until Friday November 6, 2015 to file its brief.

The State of Texas now requests a 30-day extension of time in which to file its brief.

II.

Good cause exists for allowing the State additional time to file its brief for the following reasons: 1. Counsel for the State has had a medical emergency and has been under doctor’s care, and out of the office, since Monday November 2, 2015.

2. Counsel for the Appellant is unopposed to this extension, and State’s Brief is substantively complete with additional time needed to review.

III.

From the above-listed reasons, the State has demonstrated that good cause for the failure to be able to submit its brief by the Court’s deadline. This is the State’s first motion for extension, and it is not brought for purposes of delay or harrassment, but to see that justice is done.

Wherefore, Appellee State of Texas prays that the Court grant its requested 30-day extension to file its State’s Brief in this matter.

Respectfully Submitted, /s/ April Ayers-Perez Assistant District Attorney Angelina County D.A.’s Office P.O. Box 908 Lufkin, Texas 75902 (936) 632-5090 phone (936) 637-2818 fax State Bar No. 24090975 ATTORNEY FOR THE STATE OF TEXAS

Certificate of Service I certify that on November 6, 2015, a true and correct copy of the above document has been forwarded to Al Charanza, by electronic service through efile.txcourts.gov.

/s/ April Ayers-Perez

Certificate of Conference I certify that on November 3, 2015, I conferred with Al Charanza about this motion, and certify that he was unopposed to a 30-day extension.

/s/ April Ayers-Perez