Tonya Ann Rodriguez v. State

Opinion

ACCEPTED

06-14-00190-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS 6/1/2015 4:58:15 PM

DEBBIE AUTREY

CLERK

CASE NOS. 06-14-00190-CR

In The FILED IN 6th COURT OF APPEALS

TEXARKANA, TEXAS

COURT OF APPEALS 6/1/2015 4:58:15 PM SIXTH DISTRICT OF TEXAS DEBBIE AUTREY AT TEXARKANA Clerk

TONYA ANN RODRIGUEZ, Appellant

VS.

THE STATE OF TEXAS, Appellee

On Appeal from the 354th Judicial District Court ofHuntCoun~,Texas

Trial Court Cause Nos. 29,230 Honorable Richard A. Beacom, Jr., Judge Presiding

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

NOBLE DAN WALKER, JR. District Attorney, in and for Hunt County, Texas

STEVE LILLEY Assistant District Attorney State Bar Number- 24046293 P.O. Box 441 4th Floor, Hunt County Courthouse Greenville, Texas 75401

------------------Ielepbone-Number--=-~9031-408~4-1-80--­ Facsimile Number- (903) 408-4296 Email: slilley@huntcounty.net

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

Comes now, The State of Texas, and files this, her First Motion for

Extension of Time to File State's Brief.

I.

The current filing deadline for the State's brief is June 1, 2015.

II.

The State requests this extension of time to her file her brief due to

the fact that the appellate attorney has not yet completed his work on the

brief. Between May 1 and June 1, 2015, the attorney responsible for the

brief in this case worked to complete the appeal brief in The State of Texas

v. Tyrone Denard Anderson, Cause No. 06-14-00074-CR, on May 8, 2015.

The same attorney completed findings of fact and conclusions of law for

the trial court's approval and submission to the Court of Criminal Appeals in

The State of Texas v. Willie Doss, Writ No. 82,858-01, on or about May 15,

2015. The attorney also began work on the appeal brief in The State of

Texas v. Mark Anthony Young, Cause No. 06-14-00086-CR and later filed

a request for clarification on May 18, 2015. In addition, the same attorney

_ _ _ _bas_be_en_making_finaLpreparations_for_jur:y_triaiJo_begin_Ju ne-8,-20-1-5-i 1 " 1 - - - -

The State of Texas v. Joshua Madison Newkirk, Cause No. 29,868, a

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murder case with over thirty persons under subpoena by the State ..

Ill.

The State believes that it can complete its brief in this case with an

extension to July 1, 2015, after the completion of the aforesaid murder trial.

The State therefore requests an extension until that date.

IV.

This is the State's first request for an extension.

V.

For the reasons stated hereinabove, it is respectfully requested that

this Court grant the State of Texas until July 1, 2015, to file her brief.

eve Lilley Assistant District Attorney Hunt County, Texas P.O. Box 441 Greenville, Texas 75403-0441 Phone: 903/408-4180 Fax: 903/408-4296 Email: slilley@huntcounty.net

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CERTIFICATE OF SERVICE

This is to certify that a true copy of th)9 Motion to Extend Time to File State's Brief has been forwarded to Mr. FraiJI'k L0'1Q-15 facsimile.

J)rtf -

Steve Lilley