Angela Beth Villines v. State

Opinion

ACCEPTED 06-15-00152-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 12/29/2015 3:51:51 PM DEBBIE AUTREY CLERK

NO. 06-15-00152-CR

FILED IN 6th COURT OF APPEALS IN THE COURT OF APPEALS TEXARKANA, TEXAS SIXTH APPELLATE DISTRICT OF TEXAS 12/30/2015 8:15:00 AM AT TEXARKANA DEBBIE AUTREY Clerk

ANGELINE BETH VILLINES

Appellant

v.

THE STATE OF TEXAS

Appellee

TRIAL COURT CASE NUMBER 25003

SECOND MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF

MICHAEL D. MOSHER State Bar No. 14580100 THE MOSHER JUSTICE CENTER 50 NORTH MAIN PARIS, TEXAS 75460 (903) 785-4721 TELEPHONE (903) 785-5319 FAX

ORAL ARGUMENT REQUESTED Pursuant to Appellate Rule 10.5(b), the Appellant, Angela Villines, files this request for a

14-day extension of time to file Appellant’s Brief as follows.

The Appellant’s Brief is currently due on December 30, 2015. Appellant requests a

14-day extension to file her brief, which would make the new due date January 13, 2015. This is

the second extension requested by Appellant for filing this brief. Appellant requests this

additional time to file her brief because the attorney assisting counsel in preparing the brief has

had surgery on his leg on December 9, 2015 and has missed time in the office due to the surgery

and physical therapy and counsel has been unable to adequately prepare her brief due to other

obligations, including the following:

1. Counsel’s attorney, Michael D. Mosher, was on a scheduled vacation in Istanbul

from December 3-8, 2015.

2. Preparation and attendance at a deposition on December 11, 2015 in case styled

In the Interest of Clint Wayne Freeman II and Wyhtt Freeman pending in Cause Number CV-

02143 in the 6th District Court, Red River County, Texas.

3. Appellant’s counsel’s office was closed for the Christmas holidays December 24,

2015 through December 27, 2015.

4. Appellant’s counsel’s office will be closed New Years Day January 1, 2015.

5. Preparation and attendance at mediation on January 7, 2016 in case styled

Richard Finley Vs. Sharron L. Cox, Et Al pending in Cause Number 81657 in the 62nd District

Court, Lamar Co., Texas.

This request is not made for purpose of delay, but to permit Appellant sufficient time to

prepare his brief. PRAYER

The Appellant respectfully requests that the Court grant a 14-day extension of time to file

his brief, extending the date to file the brief from December 30, 2015 until January 14, 2016.

Respectfully submitted,

THE LAW OFFICE OF MICHAEL D. MOSHER

/s/ Michael D, Mosher MICHAEL D. MOSHER STATE BAR NO. 14580100 THE MOSHER JUSTICE CENTER 50 NORTH MAIN PARIS, TEXAS 75460 (903) 785-4721 TELEPHONE (903) 785-5319 FAX E-MAIL: mdm@mosherjusticectr.com

DATE: December 29, 2015