ACCEPTED
06-15-00022-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
5/13/2015 3:09:39 PM
DEBBIE AUTREY
CLERK
FOR THE SIXTH COURT OF APPEALS
AT TEXARKANA, TEXAS
FILED IN
SONYA KAY HARGETT § 6th COURT OF APPEALS
Appellant § CASE NO. 06-15-00022-CR
TEXARKANA, TEXAS
VS. § 5/13/2015 3:09:39 PM
§ TRIAL COURT DEBBIE
NO. 09-0447X
AUTREY
STATE OF TEXAS § Clerk
Appellee §
MOTION FOR EXTENSION OF TIME TO
FILE APPELLANT’S BRIEF
TO THE HONORABLE COURT OF APPEALS:
NOW COMES, SONYA KAY HARGETT, the Appellant herein, and moves the Court
for an extension of time to file Appellant’s Brief in this cause, pursuant to Rules 38.6 and 10.5
(b) of the Texas Rules of Appellate Procedure, and in support thereof would show the Court as
follows:
I.
The Appellant in this cause was convicted in the 71st District Court, Harrison County,
Texas in cause number 09-0447X for the offense of Driving While Intoxicated- Enhanced.
II.
The Reporter’s record was filed on April 14, 2015. The Appellant’s Brief is due on or
about May 14, 2015.
III.
The Appellant hereby request an extension of time to file Appellant’s Brief. The
undersigned counsel has not had an adequate opportunity to prepare the Appellant’s Brief for the
following good and sufficient reasons:
Counsel is currently standby counsel in Cause No. 241-1467-12; State of Texas v. James
Calvert, in Smith County, Texas. In this case, the State is seeking the death penalty and Counsel
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has been in individual voir dire almost daily since April 24, 2015. Counsel request addtional
time to prepare the appellant brief. Counsel will have a break in voir dire from May 14, 2015
until May 26, 2015. This motion is not made for purposes of delay only, but in the interest of
justice, and to meet my obligations to my client and this court, and to accomplish the design of
this appeal, which to do substantial justice to appellant. Tex.R.App.P. 44(b). Counsel has not
been granted any previous extensions, therefore counsel respectfully requests an additional thirty
(30) days to prepare and file the brief herein.
WHEREFORE, PREMISES CONSIDERED, the undersigned counsel, on behalf of
Appellant, respectfully prays that this Honorable Court extend the time for filing Appellant’s
Brief for an additional thirty (30) days, to June 13, 2015.
Respectfully submitted,
____________________________
JASON D. CASSEL
Texas State Bar No. 24006970
P.O. Box 2649
Longview, Texas 75606
Telephone 903-757-8449
Facsimile 903-758-7397
ATTORNEY FOR THE APPELLATE
SONYA KAY HARGETT
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing instrument was mailed to ,
Harrison County District Attorney, P.O. Box 776, Marshall, Texas 75670, on this the 13TH day
of May, 2015.
_________________________________
JASON D. CASSEL
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FOR THE SIXTH COURT OF APPEALS
AT TEXARKANA, TEXAS
SONYA KAY HARGETT §
Appellant § CASE NO. 06-15-00022-CR
VS. §
§ TRIAL COURT NO. 09-0447X
STATE OF TEXAS §
Appellee §
ORDER
Appellant’s Motion to Extend Time to File Appellant’s Brief having been presented to
the Court; and the Court having considered same it is GRANTED. IT IS THEREFORE
ORDERED that Appellant’s Brief shall be due on or before June 13, 2015.
SIGNED this _________ day of ______________________, 2015.
___________________________________
PRESIDING JUSTICE
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