ACCEPTED
06-14-00105-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
3/6/2015 2:19:11 PM
DEBBIE AUTREY
CLERK
NO. 06-14-00105-CR
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FILED IN
IN THE COURT OF APPEALS 6th COURT OF APPEALS
TEXARKANA, TEXAS
FOR THE 3/6/2015 2:19:11 PM
SIXTH APPELLATE DISTRICT DEBBIE AUTREY
Clerk
AT TEXARKANA, TEXAS
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Timothy Paul Bates, APELLANT
V.
THE STATE OF TEXAS, APPELLEE
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APPEAL IN CAUSE NUMBER CR1301437
IN THE COUNTY COURT AT LAW #2
OF HUNT COUNTY, TEXAS
JUDGE DUNCAN THOMAS PRESIDIING
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APPELLEE MOTION FOR EXTENSION
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
NOW COMES, Joseph T. O’Neill, Appellee and Attorney for the State, makes and files
this Motion for Extension and would respectfully show the following:
I.
Appellee’s Brief is due March 5, 2015. The request for extension is made for the
following reason: Appellee maintains a regular docket in County Court at Law #2 in Hunt
County, as well as multiple Justice of the Peace courts. Trials in cause numbers
CR1400590/CR1400591, CR1401274, and CR1400453 have caused Appellee to not have the
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Motion for Continuance Page 1 of 2
time to prepare a proper breif for the court's consideration. A string of bad weather on 2/23/15,
2/24/15 and 3/5/15 have caused Appellee to not be in the office to give additional time to work
on this appeal.
II.
Appellee moves for a 30 day extension in this matter. This Motion for Extension is in the
interest of justice and not for the purpose of delay.
WHEREFORE PREMISES CONSIDERED, Appellee prays the Court grant this, its
Motion for Extension, in the above numbered cause.
Respectfully submitted,
____/S/___Joseph T. O’Neill_________
Joseph T. O’Neill
Assistant Hunt County Attorney
State Bar No. 24076953
CERTIFICATE OF SERVICE
A true and correct copy of the foregoing Motion for Extension was served on counsel
for Appellant.
___/S/___Joseph T O’Neill________
Joseph T. O’Neill
______________________________________________________________________________
Motion for Continuance Page 2 of 2