Sonya Kay Hargett v. State

Opinion

ACCEPTED 06-15-00022-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 7/1/2015 4:17:21 PM DEBBIE AUTREY CLERK

APPEAL NO. 06-15-00022-CR

SONYA KAY HARGETT § IN THE COURT OF APPEALS FILED IN 6th COURT OF APPEALS § TEXARKANA, TEXAS V. § SIXTH DISTRICT OF TEXAS 7/1/2015 4:17:21 PM § DEBBIE AUTREY STATE OF TEXAS § TEXARKANA, ClerkTEXAS

MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF

TO THE HONORABLE JUSTICES OF THE SIXTH COURT OF APPEALS:

COMES NOW, Jonathan Hyatt, and files his Motion for Extension of Time

to File Appellee’s Brief, pursuant to Rules 9 and 10 of the Texas Rules of

Appellate Procedure, and in support thereof, would show the Court the following:

I.

The Deadline for filing Appellee’s Brief is July 6, 2015.

II.

The length of the extension sought is 30 days.

III.

Appellee relies on the following facts to reasonably explain said request for an

extension:

A. Collateral duties within the District Attorney’s Office require that

counsel prepare for a jury trial with jury selection to commence on the

due date of the Appellee Brief. Said case is State v. Victor Dunn, 2014-

0838, Harrison County Court at Law.

1 B. Additional staff at the District Attorney’s office is participating in a

Capital Murder case set to begin on the due date of Appellee’s brief.

Incidentally, the Attorney for Appellant is participating in that case as

well.

IV.

This is the first request for an extension to file Appellee’s Brief.

Wherefore, premises considered, undersigned counsel prays for this Court to

extend the time for filing Appellee brief until August 5, 2015, which is thirty days

from the current deadline.

Respectfully Submitted,

/s/ Jonathan Hyatt Jonathan Hyatt State Bar No. 24072161

ATTORNEY FOR APPELLEE Harrison County District Attorney’s Office P.O. Box 776 Marshall, Texas 75671 Telephone No. (903) 935-8408 Facsimile No. (903) 938-9312 jonh@co.harrison.tx.us

2 CERTIFICATE OF CONFERENCE

As required by Texas Rule of Appellate Procedure 10.1(a)(5), I certify that I have

conferred, or made a reasonable attempt to confer, with all other parties, which are

listed below, about the merits of this motion with the following results:

Jason Cassel, Attorney for Appellant, does not oppose this Motion.

/s/ Jonathan Hyatt Jonathan Hyatt

CERTIFICATE OF SERVICE

By affixing my signature below, I, Jonathan Hyatt, hereby certify that a true copy

of Motion for Extension of Time to File Appellee’s Brief has been provided to

Jason Cassel, Attorney for Appellant, on July 1, 2015, by facsimile as provided by

Rule 9.5(b) of the Texas Rules of Appellate Procedure.