Brian Eugene Woodard v. State

ACCEPTED 06-14-00221-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 7/1/2015 2:58:01 PM DEBBIE AUTREY CLERK CASE NO. 06-14-00221-CR In The FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS COURT OF APPEALS 7/1/2015 2:58:01 PM SIXTH DISTRICT OF TEXAS DEBBIE AUTREY AT TEXARKANA Clerk BRIAN EUGENE WOODARD, Appellant VS. THE STATE OF TEXAS, Appellee On Appeal from the 354th Judicial District Court of Hunt County, Texas Trial Court Cause No. 29,390 Honorable Richard A. Beacom, Jr. Judge Presiding MOTION FOR EXTENSION OF TIME TO FILE STATE'S BRIEF NOBLE DAN WALKER, JR. District Attorney, in and for Hunt County, Texas KELI M. AIKEN Assistant District Attorney State Bar Number- 24043442 P.O. Box 441 4th Floor, Hunt County Courthouse Greenville, Texas 75401 Telephone Number- (903) 408-4180 Facsimile Number- (903) 408-4296 kaiken@huntcounty.net MOTION FOR EXTENSION OF TIME TO FILE STATE'S BRIEF Comes now, The State of Texas, and files this, her Motion for Extension of Time to File State's Brief. I. The current filing deadline for the State's brief was June 25, 2015. II. The State requests a two week extension to file her brief, that is, until July 10, 2015. Ill. The State requests an extension because the case was previously tried and assigned to a prosecutor who is no longer with our office. We discovered today that the brief was due last Thursday and we will need a few days to get the record from the court reporter, review the file and brief and prepare a response. It is our plan to start working on the appeal immediately and file it as soon as we can get it finished. IV. The State has made no previous requests for extensions to file her brief. V. We attempted to contact Mr. Perry, Appellant's counsel and left a message for him but were unable to conference with him prior to the filing of this motion. VI. For the reasons stated hereinabove, it is respectfully requested that this Court grant the State of Texas until July 10, 2015, to file her brief. Respectfully submitted, /s/ Keli M. Aiken Keli M. Aiken First Assistant District Attorney Hunt County, Texas P.O. Box 441 Greenville, Texas 75403-0441 Phone: 903/408-4180 Fax: 903/408-4296 kaiken@huntcounty.net CERTIFICATE OF CONFERENCE I certify that I attempted to reach Mr. Perry today, June 29, 2015 on his office number and also on his cell number. I left him a message on his cell and stated the reason for my call as well as my return office and cell numbers. Is/ Keli M. Aiken Keli M. Aiken CERTIFICATE OF SERVICE This is to certify that a true copy of this Motion to Extend Time to File State's Brief has been faxed to Mr. Perry at 903/886-2043. /s/ Keli M. Aiken Keli M. Aiken