ACCEPTED
06-14-00053-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
2/11/2015 4:53:20 PM
DEBBIE AUTREY
CLERK
IN THE COURT OF APPEALS FOR THE
SIXTH DISTRICT OF TEXAS
FILED IN
6th COURT OF APPEALS
TEXARKANA, TEXAS
ANTHONY DAVID TEAGUE, §
2/11/2015 4:53:20 PM
APPELLANT §
DEBBIE AUTREY
§ Clerk
V. § No. 06-14-00053-CR
§
THE STATE OF TEXAS, §
APPELLEE §
SECOND MOTION FOR EXTENSION OF TIME
TO FILE STATE’S BRIEF
COMES NOW, The State of Texas, by and through the Criminal District
Attorney of Collin County, Greg Willis, and tenders, pursuant to Texas Rule of
Appellate Procedure 38.6(d), this second motion for an extension of time to file
the State’s brief. In support of this motion, the State would show the following:
I.
The Court below is the 219th District Court Judicial District Court of Collin
County. The style and number of this case in the court below is The State of
Texas v. Anthony David Teague, 366-82919-2013.
II.
Appellant was convicted of stalking and sentenced to 20 years’
confinement.
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III.
The State’s brief is due on February 11, 2015. The State request that it be
granted an extension until March 13, 2015. The State has previously requested one
extension of time in these cases.
IV.
The case is not yet set for submission.
V.
Counsel has substantial day to day management duties as chief of the
appellate division of the Collin County District Attorney’s Office. These include
trial support for ongoing prosecutions, legal advice to the elected district attorney,
and representing the State in various hearings in the Collin County trial courts, as
well as editing and reviewing work product produced by the four attorneys under
counsel’s supervision.
Since the State requested its initial extension on January 28, 2015, counsel
has engaged in the following matters:
I filed the State’s briefs in Joe Polanco v. State, Nos. 05-14-00212-CR &
05-14-00213-CR on January 30, 2015.
I filed a writ response in Ex parte Samuel Wade Dooley, No. W401-81397-
00-HC on January 29, 2015.
I filed responses to petitions for non-disclosure in the following cases:
Defendant Cause Number Answer Filed
Moore 002-00267-2015 2/3/2015
Moosa 001-00263-2015 2/3/2015
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Hexamer 416-00375-2015 2/3/2015
Hong 001-00220-2015 2/3/2015
Dal-Bello 002-00217-2015 2/3/2015
Punyamurthy 002-00221-2015 2/3/2015
Shilleh 006-00216-2015 2/3/2015
Dudley 004-00180-2015 2/3/2015
Parrack 005-00183-2015 2/3/2015
Williams 003-00332-2015 2/7/2015
Hornaday 001-00302-2015 2/7/2015
Fife 366-00437-2015 2/7/2015
White 003-00283-2015 2/7/2015
Taiwo 001-00195-2015 2/7/2015
Bearce-Bellow 219-00190-2015 2/7/2015
Counsel was involved in a hearing regarding possible jury misconduct and
a charging conference on February 2, 2015, in a capital murder case where the
State waived the death penalty, Melinda Muniz v. State, No. 401-80836-2014.
Counsel is required to appear before the 422nd District Court in Kaufman
County on February 24-25 for a motion for new trial hearing in Eric Lyle Williams
v. State, No. 32022-422, a death penalty case in which counsel is acting as a
special prosecutor appointed by that Court.
VI.
Appellant received four extensions of time to file his brief totaling
approximately 96 days.
V.
Counsel has conferred with Appellant’s counsel, Shawn Ismail, via
electronic mail regarding this motion. Mr. Ismail stated that he has no objection to
the State’s motion.
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WHEREFORE, premises considered, the State respectfully requests that the
court grant an extension of time for the State to file its brief until March 13, 2015.
Respectfully submitted,
/s/ John R. Rolater, Jr.
John R. Rolater, Jr.
Assistant District Attorney
State Bar No. 00791565
2100 Bloomdale Rd., Ste. 200
McKinney, Texas 75071
(972) 548-4323
(214) 491-4860
CERTIFICATE OF SERVICE
A true copy of this First Motion for Extension of Time to File the State’s
Brief was served on counsel for Appellant, Shawn Ismail, at
shawnismail@gmail.com, on February 11, 2015.
/s/ John R. Rolater, Jr.
John R. Rolater, Jr.
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