`04-22-00243-CR
`FOURTH COURT OF APPEALS
`SAN ANTONIO, TEXAS
`11/2/2022 3:38 PM
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`Cause No. 04-22-00243-CR
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`IN THE FOURTH COURT OF APPEALS
`SAN ANTONIO, TEXAS
`____________________________________________________________
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` EMERY RAY MENCHACA,
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`Appellant
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`v.
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`THE STATE OF TEXAS,
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`Appellee
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`______________________________________________________________________________
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`On Appeal from the 81st/218th District Court
`Atascosa County, Texas
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`STATE’S FIRST MOTION FOR EXTENSION
`OF TIME TO FILE RESPONSE TO APPELLANT’S BRIEF
`______________________________________________________________________________
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`AUDREY GOSSETT LOUIS
`District Attorney
`81st JUDICIAL DISTRICT OF TEXAS
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`J. WILLIAM RICHMOND
`Assistant District Attorney
`81st / 218th JUDICIAL DISTRICT OF TEXAS
`1105 A STREET
`Floresville, Texas 78026
`Tele: (830) 393-2200
`Fax: (830) 393-2205
`E-Mail: william.richmond@81stda.org
`State Bar No. 24085552
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`Attorneys for the State of Texas
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` FILED IN
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`4th COURT OF APPEALS
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` SAN ANTONIO, TEXAS
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`11/2/2022 3:38:43 PM
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` MICHAEL A. CRUZ
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` Clerk
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`STATE’S FIRST MOTION FOR EXTENSION
`OF TIME TO FILE BRIEF
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`The State of Texas, under the authority of Rules 10.5(b) and 68.2(c), Texas Rules
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`of Appellate Procedure, asks the Court to extend time to file the State’s Response from
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`November 2, 2022, up to and including December 2, 2022, a period of 30 days.
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`1.
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`2.
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`The State’s Brief is presently due on August 23, 2022.
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`The State respectfully requests an additional 30 days to file its brief, that is, an
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`extension of time until December 2, 2022.
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`3. No previous extension has been requested by the State.
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`4.
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`The State of Texas requests this extension based on the following reasons:
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`A.
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`The 81st Judicial District Attorney’s Office covers five (5) counties and
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`over two hundred miles. The attorney for the State handles all asset
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`forfeiture cases, bond forfeiture cases, requests for records under the
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`Texas Public Information Act and appeals for all 5 counties within the 81st
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`B.
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`C.
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`Judicial District.
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`Opposing counsel has no objections to the State's motion.
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`Extension is justified by the present workload for the undersigned
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`attorney, and requires additional time to compose a brief that will
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`adequately assist the Court in reviewing this case and rendering an
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`opinion.
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`D.
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`Due to the serious nature of Appellant’s crime and conviction, the State
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`wishes to take the time to fully and adequately research and address all
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`issues presented in the appellant’s brief.
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`For these reasons, the State asks the Court to grant an extension of 30 days to
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`December 2, 2022, within which the State may file its brief in this cause.
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`Respectfully submitted,
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`Audrey Gossett Louis
`District Attorney
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`/S/ J. WILLIAM RICHMOND
`J. William Richmond.
`Assistant District Attorney
`81st JUDICIAL DISTRICT OF TEXAS
`1105 A. STREET
`Floresville, Texas 78026
`Telephone (830) 393-2200
`Telecopier (830) 393-2205
`Email: william.richmond@81stda.org
`TEXAS BAR NUMBER 24085552
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`Attorneys for the State of Texas
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`CERTIFICATE OF SERVICE
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`I certify that the foregoing instrument has been served on opposing counsel, John
`Lamerson, The Lamerson Law Firm, P.O. Box 241, Corpus Christi, Texas 78403, via
`email at lamersonlawfirm@gmail.com on November 2, 2022.
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`/s/ J. William Richmond
`JOHN WILLIAM RICHMOND
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`Automated Certificate of eService
`This automated certificate of service was created by the efiling system.
`The filer served this document via email generated by the efiling system
`on the date and to the persons listed below. The rules governing
`certificates of service have not changed. Filers must still provide a
`certificate of service that complies with all applicable rules.
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`Envelope ID: 69816453
`Status as of 11/2/2022 3:46 PM CST
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`Associated Case Party: EmeryJayMenchaca
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`Name
`John Lamerson
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`BarNumber Email
`lamersonlawfirm@gmail.com
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`TimestampSubmitted
`11/2/2022 3:38:43 PM
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`Status
`SENT
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