Jeff Ellis Nanny v. State

ACCEPTED 03-16-00196-CR

12583961 THIRD COURT OF APPEALS

AUSTIN, TEXAS 9/8/2016 10:11:37 AM

JEFFREY D. KYLE

CLERK

NO. 03-16-00196-CR

JEFF ELLIS NANNY IN THE FILED IN

3rd COURT OF APPEALS

AUSTIN, TEXAS V. THIRD COURT9/8/2016

OF APPEALS

10:11:37 AM JEFFREY D. KYLE

THE STATE OF TEXAS AUSTIN, TEXAS Clerk

STATE'S MOTION FOR EXTENSION OF TIME TO FILE BRIEF TO THE HONORABLE THIRD COURT OF APPEALS:

NOW COMES the State of Texas, Appellee in the above entitled and numbered cause and files this Motion for Extension of Time to File State’s Brief, and in support thereof would show the Court the following:

I.

Appellant was found guilty by the Court of possession of a controlled substance, a state jail felony, and the Judge assessed punishment at 600 days confinement in the State Jail Division of the Texas Department of Criminal Justice on March 17, 2016. Appellant filed Notice of Appeal on March 23, 2016. Appellant's brief was filed on August 10, 2016. The State's brief is currently due on September 9, 2016.

II.

The State has not requested an extension in this case prior to this request.

III.

The State requests this extension of time due to the following: Counsel for the State has been involved in prosecution of cases including contested hearings, pretrial hearings, grand jury presentation, negotiations with opposing counsel, guilty pleas and other hearings in numerous additional pending felony cases.

WHEREFORE, The Attorney for the State requests an extension of time to October 11, 2016, in which to file State's Brief.

Respectfully submitted, _______________________ Jason Ferguson Assistant District Attorney 119th Judicial District 124 W. Beauregard, Suite B San Angelo, TX 76903 (325) 659-6583 State Bar No. 24072092

SWORN TO AND SUBSCRIBED before me by the said Meagan White, this 8th day of September, A. D. 2016.

_______________________ Notary Public State of Texas

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing Motion for Extension of Time to File Appellee's Brief was this 8th day of September, 2016, delivered to Tom Watson, Attorney for Appellant, through e-file.txcourts.gov.

_______________________ Jason Ferguson