Travis Bell v. State

Opinion

ACCEPTED

02-17-00299-CR

SECOND COURT OF APPEALS

FORT WORTH, TEXAS

5/25/2018 12:54 PM

DEBRA SPISAK

CLERK

IN THE COURT OF APPEALS

FOR THE

SECOND COURT OF APPEALS DISTRICT OF TEXAS FILED IN

2nd COURT OF APPEALS

FORT WORTH, TEXAS

TRAVIS BELL, § 5/25/2018 12:54:45 PM DEBRA SPISAK

APPELLANT § Clerk

§ NO. 02-17-00299-CR V. § §

THE STATE OF TEXAS, § APPELLEE §

STATE'S FIRST MOTION FOR EXTENSION OF TIME TO FILE ITS BRIEF ON APPEAL

TO THE HONORABLE COURT OF APPEALS:

The State requests that the Court grant a 30-day extension of time for the filing of the State’s brief in this case. The following allegations are made in support of this motion:

-I-

The court below is the County Criminal Court No. 10 of Tarrant County, Texas. The style and number of the case in the trial court is The State of Texas v. Travis Bell, No. 1478469.

- II -

Appellant was convicted of a DWI misdemeanor offense and is not incarcerated.

- III -

Appellant filed his brief on April 27, 2018.

- IV -

The current deadline for filing the State’s brief is May 29, 2018.

-V-

The State has no extensions in this case. Two motions for extension were granted to Appellant.

- VI -

The submission date in this case is not set. Therefore, this requested extension will not delay submission. Counsel has been tasked with a number of projects following his release from the hospital and has been unable to complete this instant brief for that reason.

- VII -

WHEREFORE, PREMISES CONSIDERED, the State of Texas prays that this Court grant this State’s First Motion for Extension of Time to File its Brief on Appeal and extend the time for filing of the State’s brief to Thursday, June 28, 2018.

Respectfully submitted,

SHAREN WILSON

Criminal District Attorney Tarrant County, Texas

3

JOE SPENCE, Assistant

Criminal District Attorney Chief, Post-Conviction

/s/ David L. Richards

DAVID L. RICHARDS, Assistant Criminal District Attorney State Bar No. 16845500

401 W. Belknap

Fort Worth, Texas 76196-0201 (817) 884-2824

FAX (817) 884-1672

COAappellatealerts@tarrantcountytx.gov

CERTIFICATE OF CONFERENCE The undersigned spoke with a staff member for Dean Miyazono, counsel for Appellant, who stated that Mr. Miyazono does not oppose this extension.

/s/ David L. Richards

DAVID L. RICHARDS

CERTIFICATE OF SERVICE

A true copy of the State’s motion has been e-served to opposing counsel, Hon.

Dean Miyazono, 1300 S. University Dr., Ste. 602, Fort Worth, Texas, 76107, email: ftwdwi@gmail.com, this 25th day of May, 2018.

/s/ David L. Richards

DAVID L. RICHARDS