ACCEPTED 03-15-00153-CR 8268787 THIRD COURT OF APPEALS AUSTIN, TEXAS 12/16/2015 3:26:16 PM JEFFREY D. KYLE CLERK

No. 03-15-00153-CR FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 12/16/2015 3:26:16 PM IN THE COURT OF APPEALS FOR THE THIRD JEFFREY D. KYLE DISTRICT OF TEXAS Clerk

.THE STATE OF TEXAS, Appellant v. FRANCES ANITA ROBINSON, Appellee

On Appeal from the 207th Judicial District Court of Comal County, Texas Cause No. CR2013-267 Honorable Bruce Boyer, District Judge Presiding

MOTION TO EXTEND TIME TO FILE APELLEE'S BRIEF

Sullivan & Associates, PLLC By Charles Sullivan Texas Bar No. 24049421 Campbell Drive Canyon Lake, TX 78133 (830) 899-3259 Phone (210) 579-6448 Fax [email protected] Attorney for Appellee Robinson MOTION TO EXTEND TIME TO FILE APPELLEE'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: Now comes Francis Anita Robinson, Appellee in the above styled and numbered cause, and moves this Court to grant an extension of time to file appellant's brief, pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good cause shows the following: 1. This case is on appeal from the 207th Judicial District of Comal County, Texas.

2. The case below was styled the STATE OF TEXAS vs. FRANCES ANITA ROBINSON, and numbered CR2013-267.

3. Appellant State is appealing Motion to Supress Evidence granted by the trial court on February 18,2015.

4. The appellate filed their brief on October 16, 2015.

5. Appellee requests an extension of time of30 days from the current due date, i.e., December 21, 2015.

6. Appelle has previously requested one extension on November 19, 2015 which was granted.

7. Defendant is currently free on bond.

WHEREFORE, PREMISES CONSIDERED, Appellee prays that this Court grant this Motion To Extend Time to File Appellee's Brief, and for such other and further

No. 03-15-00153-CR, State v Robinson, Motion to Extend Time to File Appellee's Brief relief as the Court may deem appropriate.

Respectfully submitted,

Char~l ivan Texas Bar No. 24049421 Sullivan & Associates, PLLC Campbell Drive Canyon Lake, TX 78133 (830) 899-3259 Phone (21 0) 579-6448 Fax

STATE OF TEXAS § § COUNTY OF COMAL §

AFFIDAVIT BEFORE ME, the undersigned authority, on this day personally appeared Charles Sullivan, who after being duly sworn stated: "I am the attorney for the appellant in the above numbered and entitled cause. I have read the foregoing Motion To Extend Time to File Appellant's Brief and swear that all of the allegations of fact contained therein are true and correct."

No. 03-15-00153-CR, State v Robinson, Motion to Extend Time to File Appellee's Brief SUBSCRIBED AND SWORN TO BEFORE ME on December 16, 2015, to certify which witness my hand and seal of office.

- Certificate of Service I, Charles Sullivan, attorney for Frances Anita Robinson, Appellee, hereby certify that a true and correct copy of this Motion has been delivered to Appellant via State's attorney of record in this matter: Jennifer Tharp, Criminal District Attorney Daniel Palmitier, Assistant District Attorney N. Seguin Avenue, Suite #307 New Braunfels, Texas 78130 (830) 221-1300 Fax (830) 608-2008 E-mail: preslj @co.comal. tx. us Attorneys for State By electronically sending it through efile.txcourts.gov service, this l6 1h day of December, 2015. . f}J~ Charles Sullivan

No. 03-15-00153 -CR, State v Robinson, Motion to Extend Time to File Appellee's Brief