ACCEPTED 01-15-00206-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 10/15/2015 4:01:05 PM CHRISTOPHER PRINE CLERK No. 01-15-00206-CR IN THE COURT OF APPEALS FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS FIRST JUDICIAL DISTRICT 10/15/2015 4:01:05 PM CHRISTOPHER A. PRINE HOUSTON, TEXAS Clerk __________________________________________________________ No. 17166 IN THE 253RD DISTRICT COURT OF CHAMBERS COUNTY, TEXAS __________________________________________________________ CODY CRYMES § Appellant v. § STATE OF TEXAS § Appellee __________________________________________________________ STATE'S MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO APPELLANT’S MOTION FOR REHEARING __________________________________________________________ Cheryl Swope Lieck District Attorney Chambers County, Texas Kathy Esquivel Assistant District Attorney Chambers County, Texas P.O. Box 1409 Anahuac, Texas 77514 (409) 267-2682 (409) 267-3105 [email protected] COMES NOW the State of Texas, by and through her Assistant District Attorney, Kathy Esquivel, and, pursuant to TEX. R. APP. PRO. 73, presents this Motion for Extension of Time. In support of the motion, the State submits the following: 1. The above case is on appeal from a plea of guilty in the 253rd Judicial District Court of Chambers County, Texas.

2. The State’s response is currently due on October 20, 2015.

3. This is the State’s first Motion for Extension of Time.

4. Counsel for the State was preparing for another jury trial in the 253rd District Court and did not have adequate time to complete the brief in this case.

Further, counsel for the State was preparing a case for a special meeting of the grand jury.

5. The State requests that the time for filing the State’s Brief be extended by 7 days to October 27, 2015. The State requests this extension not for delay, but to see that justice is done.

WHEREFORE, PREMISES CONSIDERED, the State prays that this Court grant the State’s Motion for Extension of Time and extend the due date of the State’s Appellate Brief until October 27, 2015.

Respectfully submitted, CHERYL SWOPE LIECK Chambers County District Attorney

/s/ Kathy Esquivel KATHY ESQUIVEL Assistant District Attorney Chambers County, Texas P.O. Box 1409 Anahuac, Texas 77514 (409) 267-2682 (409) 267-3105 FAX SBN 24034432 [email protected]

CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing instrument has been sent to opposing counsel via email on ___15th_____ day of October, 2015.

/s/ Kathy Esquivel KATHY ESQUIVEL Assistant District Attorney Chambers County, Texas

Rick Oliver Attorney for Appellant