Cody Lang Thomas v. State

ACCEPTED 06-14-00110-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 5/28/2015 10:31:03 AM DEBBIE AUTREY CLERK NO. 06-14-00110-CR CODY LANG THOMAS § IN THE FILED IN § 6th COURT OF APPEALS v § 6th COURT TEXARKANA, TEXAS § 5/28/2015 10:31:03 AM STATE OF TEXAS § OF APPEALS DEBBIE AUTREY Clerk MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: Now comes The State of Texas, Appellee in the above styled and numbered cause, and moves this Court to grant an extension of time to file Appellee’s brief, pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good cause shows the following: 1. This case is on appeal from the 8th Judicial District Court of Hopkins County, Texas. 2. The case below was styled the STATE OF TEXAS vs. CODY LANG THOMAS and numbered as 1423904. 3. The Appellant was convicted and sentenced by the judge to 20 years in the penitentiary after pleading guilty and going “open” to the court for punishment. 4. The Appellee’s brief was due on May 27, 2015. Appellee requests an extension time of approximately thirty (30) days from the present date, i.e. June 27, 2015. 6. No previous extensions to file the brief have been received by Appellee in this cause. 7. Appellee requests a thirty (30) day extension due to the following: i. Appellee’s attorney is currently preparing for a murder trial beginning on June 8, 2015 in the 8th Judicial District Court entitled State of Texas v. Roy Dean Duffey, which is a retrial of a murder occurring in 2011. The previous conviction was reversed and remanded by this Court. ii. Appellee’s attorney has been preparing and did, in fact, try Motions to Proceed and Motions to Revoke on six cases entitled State of Texas v. Tony Dewayne Thomas, which was specially set the date this brief was due. (May 27, 2015) WHEREFORE, PREMISES CONSIDERED, Appellee prays that this Court grant this Motion to Extend Time to File Appellee’s Brief, and for such other and further relief as the Court may deem appropriate. Respectfully submitted, By: //s// Will Ramsay Will Ramsay 8th Judicial District Attorney State Bar No. 24039129 P.O. Box 882 110 Main Street Sulphur Springs, TX 75482 Ph: (903) 885-0640 Fax: (903) 885-0641 wramsay@hopkinscountytx.org Attorney for Appellee CERTIFICATE OF SERVICE   I hereby certify that a copy of the above and foregoing MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF was delivered via email to Martin Braddy, Attorney for Appellant, on May 28, 2015. //s//Will Ramsay WILL RAMSAY—Attorney for the Appellee