Randyael Dontrell Tyson v. State

Court of Appeals of Texas·Decided February 23, 2015·No. 06-14-00114-CR·Published

Opinion

ACCEPTED

06-14-00114-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

2/23/2015 9:16:39 AM

DEBBIE AUTREY

CLERK

ORAL ARGUMENT WAIVED

CAUSE NO. 06-14-00114-CR FILED IN 6th COURT OF APPEALS

TEXARKANA, TEXAS

IN THE 2/23/2015 9:16:39 AM DEBBIE AUTREY

COURT OF APPEALS Clerk

SIXTH APPELLATE DISTRICT OF TEXAS AT TEXARKANA

RANDYEAL DONTRELL TYSON, Appellant V.

THE STATE OF TEXAS, Appellee

ON APPEAL FROM THE COUNTY COURT AT LAW LAMAR COUNTY, TEXAS

TRIAL COURT NO. 61504; HONORABLE BILL HARRIS, JUDGE

APPELLEE’S (STATE’S) MOTION TO AMEND, SUPPLEMENT OR REDRAW APPELLANT’S BRIEF

Gary D. Young, County and District Attorney Lamar County and District Attorney’s Office Lamar County Courthouse

119 North Main

Paris, Texas 75460

(903) 737-2470

(903) 737-2455 (fax)

ATTORNEYS FOR THE STATE OF TEXAS ORAL ARGUMENT WAIVED

CAUSE NO. 06-14-00114-CR

IN THE

COURT OF APPEALS

SIXTH APPELLATE DISTRICT OF TEXAS AT TEXARKANA

RANDYEAL DONTRELL TYSON, Appellant V.

THE STATE OF TEXAS, Appellee

ON APPEAL FROM THE COUNTY COURT AT LAW LAMAR COUNTY, TEXAS

TRIAL COURT NO. 61504; HONORABLE BILL HARRIS, JUDGE

APPELLEE’S (STATE’S) MOTION TO AMEND, SUPPLEMENT OR REDRAW APPELLANT’S BRIEF

TO THE HONORABLE COURT OF APPEALS:

COMES NOW, the State of Texas, by and through Gary D. Young, the elected County and District Attorney of Lamar County, Texas and the Lamar County and District Attorney’s Office, respectfully submits this Motion to Extend Time to File Brief under Tex. R. App. P. 10 and 38. The State of Texas moves this Court pursuant to the Texas Rules of Appellate Procedure

for an extension of time in which to file the Appellee’s (State’s) Brief upon good cause shown below.

I.

On or about December 19, 2014, the appellant filed his brief in the above-styled and numbered appellate cause. As the appellee, the State filed its brief on February 10, 2015.

On or about February 18 or 20th of 2015, the County Clerk of Lamar County filed a supplemental clerk’s record that included a bill of costs. See Supp. CR, pg. 3.

II.

With his fourth issue, the appellant, Tyson, alleged that the record did not contain a certified bill of costs; therefore, Tyson cannot be made to pay costs of court. See Appellant’s Brief, pgs. 4, 20. Since the filing of Tyson’s brief, however, the County Clerk of Lamar County filed a supplemental clerk’s record that included a bill of costs. See Supp. CR, pg. 3.

III.

Under the authority of Rule 38.9 of the Texas Rules of Appellate Procedure, the State asks this Court to order the appellant (Tyson) to amend, supplement or redraw his brief. See Tex. R. App. P. 38.9 (“Because briefs

are meant to acquaint the court with the issues in a case and to present argument that will enable the court to decide the case, substantial compliance with this rule is sufficient, . . .”). Now that the County Clerk has filed a supplemental clerk’s record on or about February 20th, that included a bill of costs, the appellant, Tyson, should amend, supplement or redraw his brief with respect to the fourth issue/point of error. See id.

In the alternative, the State asks this Court to hold that the appellant’s, Tyson’s, fourth issue/point of error is now moot.

IV.

The purpose of this motion is not for delay because the above-styled and numbered cause is not set for submission until March 3, 2015, but so that justice may be had by all parties.

WHEREFORE PREMISES CONSIDERED, the State of Texas prays that upon final submission of this motion to this Court’s motion docket, this Court grant the State’s Motion to Amend, Supplement or Redraw Appellant’s Brief; or in the alternative, this Court should that the appellant’s, Tyson’s, fourth and final issue should be moot; and for such other and further relief, both at law and in equity, to which it may be justly and legally entitled.

Respectfully submitted,

Gary D. Young

Lamar County & District Attorney Lamar County Courthouse

119 North Main

Paris, Texas 75460

(903) 737-2470

(903) 737-2455 (fax)

By:________________________________ Gary D. Young, County Attorney SBN# 00785298

ATTORNEYS FOR STATE OF TEXAS CERTIFICATE OF SERVICE

This is to certify that in accordance with Tex. R. App. P. 9.5, a true copy of the “Appellee’s (State’s) Motion to Amend, Supplement or Redraw the Appellant’s Brief” has been served on the 23rd day of February, 2015 upon the following:

Don Biard

McLaughlin Hutchison & Biard LLP 38 First Northwest

Paris, TX 75460

GARY D. YOUNG

Free access — add to your briefcase to read the full text and ask questions with AI

Randyael Dontrell Tyson v. State, (Tex. Ct. App. 2015).

Randyael Dontrell Tyson v. State (Randyael Dontrell Tyson v. State) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.