Arianna Lindsey v. State

Opinion

ACCEPTED

05-14-00517-CR

FIFTH COURT OF APPEALS

DALLAS, TEXAS

10/6/2015 3:25:38 PM

LISA MATZ

CLERK

NO. 05-14-00517-CR

ARIANNA LINDSAY § IN THE COURT OF APPEALS FILED IN

5th COURT OF APPEALS

vs. § FOR THE FIFTH DISTRICT DALLAS, TEXAS

THE STATE OF TEXAS § 10/6/2015 OF TEXAS AT3:25:38

DALLASPM

LISA MATZ

Clerk

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

TO THE HONORABLE JUDGES OF SAID COURT:

THE STATE OF TEXAS, by and through the Criminal District Attorney of

Dallas County, respectfully requests that the time for filing the State’s brief be

extended from April 29, 2015 to October 6, 2015. See TEX. R. APP. P. 38.6(d). In

support of this motion, the State would show the following:

Appellant entered a plea of guilty the offense of causing serious bodily injury to

a child. After a punishment hearing, the trial court sentenced appellant to eighteen

years’ imprisonment. Judgment was entered on April 3, 2014. Appellant’s brief was

originally due on October 29, 2014. After requesting and receiving two extensions,

Appellant’s brief was ultimately filed on February 28, 2015. After requesting and

receiving one thirty-day extension, the State’s brief was due, under Rule 38.6(b) of the

Texas Rules of Appellate Procedure, on April 29, 2015. This case will be submitted to

the Court on November 4, 2015.

Good cause justifies the granting of this extension. Due to this attorney’s

existing docket, the State requests an extension of time from April 29, 2015 until

October 6, 2015, in which to file its brief. Counsel has prepared the State’s brief in

this case as expeditiously as possible without sacrificing quality and tenders the brief

for filing with this motion.

WHEREFORE, PREMISES CONSIDERED, the State respectfully requests that

the time for filing its brief be extended until October 6, 2015.

Respectfully submitted,

Susan Hawk Laura Anne Coats Criminal District Attorney Assistant District Attorney Dallas County State Bar No. 00790476 Frank Crowley Courts Building 133 N. Riverfront Blvd.,LB19 Dallas, Texas 75207-4399 (214) 653-3625 (214) 653-3643 fax

LAURA.COATS@dallascounty.org

CERTIFICATE OF SERVICE

I hereby certify that a true copy of the foregoing was served on Riann C.

Moore, Counsel for Appellant, Dallas County Public Defender’s Office by email pursuant to the efiling system on at Riann.Moore@dallascounty.org, on October 6, 2015.

Laura Anne Coats

CERTIFICATE OF WORD COMPLAINCE

I hereby certify that the foregoing motion is 393 words in length according to Microsoft Word, which was used to prepare the brief. See Tex. R. App. P. 73.3; Tex. R. App. P. 73.1(f).

__________________________________

LAURA ANNE COATS