ACCEPTED

06-14-00079-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

NO. 06-14-00079-CR 3/3/2015 2:06:31 PM

DEBBIE AUTREY

CLERK JUSTIN SANDERS * ON APPEAL FROM THE

Appellant *

FILED IN

* 102ND6th COURT OF

JUDICIAL APPEALS

DISTRICT

TEXARKANA, TEXAS VS. * 3/3/2015 2:06:31 PM STATE OF TEXAS * COURT OFDEBBIE

BOWIEAUTREY

COUNTY

Clerk

Appellee * TEXAS

MOTION TO EXTEND LENGTH OF STATE’S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT:

COMES NOW the State of Texas by and through her below named Assistant Criminal District Attorney and pursuant to the Texas Rules of Appellate Procedure and hereby requests an additional 5,000 words to respond to Appellant’s brief and in support of the same would show the Court as follows:

I.

1. This case is pending from the 102nd Judicial District of Bowie County, Texas. The date of the judgment is April 2, 2014.

2. The case is styled State of Texas v. JUSTIN SANDERS, Cause Number 13F-1051-102.

3. Appellant was convicted of the offenses of MURDER

4. Punishment was assessed at thirty (30) years in the Institutional Division of the Texas Department of Criminal Justice and a $5,000 fine.

5. Rule 9.4(i)(2)(B) of the Rules of Appellate Procedure limits a response brief in the court of appeals to 15,000 words if computer generated.

6. Rule 9.4(i)(4) of the Rules of Appellate Procedure states, “A court may, on motion, permit a document that exceeds the proscribed limit.”

7. The State requests an extension on the maximum length of State’s Brief for the following reasons:

 The record in this case consists of fifteen (15) volumes.

 Appellant filed a brief alleging eight (8) points of error and containing 14, 909 words.

 Despite multiple attempts to condense, the incomplete rough draft of the State’s

replies to the eight (8) alleged points of error is currently over 19,000 words including

citations to the law and the record. This rough draft does not yet contain a response to all

arguments made in Appellant’s Brief.

 In order to adequately respond to Appellant’s eight (8) alleged points of error along

with the arguments and cases cited within, the State requires additional words beyond the

15,000 word limit proscribed by Rule 9.4(i)(2)(B).

PRAYER

WHEREFORE, on the bases of Rule 9.4 of the Texas Rules of Appellate Procedure, the State respectfully requests this Court to grant the Motion to Extend Length of State’s Brief.

Respectfully submitted,

/s/ Samantha J. Oglesby

SAMANTHA J. OGLESBY

Texas Bar No. 24070362

601 Main Street

Texarkana, TX 75501

ATTORNEY FOR THE STATE

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and foregoing Motion to Extend Length of State’s Brief was forwarded to Mr. Craig Henry, counsel for Appellant, on this the 3rd day of March, 2015.

/s/ Samantha J. Oglesby

SAMANTHA J. OGLESBY