Damion Dewayne Williams v. State

ACCEPTED
06-14-00219-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
5/1/2015 5:31:48 PM
DEBBIE AUTREY
CLERK

APPEAL NO. 06-14-00219-CR

DAMION DEWAYNE WILLIAMS § IN THE COURT OF APPEALS
FILED IN
6th COURT OF APPEALS
§ TEXARKANA, TEXAS
V. § SIXTH DISTRICT OF TEXAS
5/1/2015 5:31:48 PM
§ DEBBIE AUTREY
STATE OF TEXAS § TEXARKANA, ClerkTEXAS

MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF

TO THE HONORABLE JUSTICES OF THE SIXTH COURT OF APPEALS:

COMES NOW, Jonathan Hyatt, and files his Motion for Extension of Time

to File Appellee’s Brief, pursuant to Rules 9 and 10 of the Texas Rules of

Appellate Procedure, and in support thereof, would show the Court the following:

I.

The Deadline for filing Appellee’s Brief is May 7, 2015.

II.

The length of the extension sought is 30 days.

III.

Appellee relies on the following facts to reasonably explain said request for an

extension:

A. Due to staff changes within the Harrison County District Attorney’s

office, namely that the former chief appellate attorney accepted

employment in a neighboring county, the appeal workload has shifted to

other members of the District Attorney’s Office that have numerous

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 collateral duties. In the time requested for said extension, the new

appellate attorney for the County will have begun employment.

B. Counsel will be second chairing a jury trial beginning May 4, 2015 in the

Harrison County Court at Law in State v. Amy Anderson, Cause Number

2014-0915, and preparation for the jury trial precludes Counsel from

adequately writing the Appellee Brief.

C. Counsel presently has another appeal brief due on May 4, 2015 in the

Sixth Court of Appeals of Texas in Jamie Lee Bledsoe v. State, Appellate

Case Number 06-14-00138-CR.

IV.

This is the first request for an extension to file Appellee’s Brief.

Wherefore, premises considered, undersigned counsel prays for this Court to

extend the time for filing Appellee brief until June 6, 2015, which is thirty days

from the current deadline.

Respectfully Submitted,

/s/ Jonathan Hyatt
Jonathan Hyatt
State Bar No. 24072161

ATTORNEY FOR APPELLEE
Harrison County District Attorney’s Office
P.O. Box 776
Marshall, Texas 75671
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 Telephone No. (903) 935-8408
Facsimile No. (903) 938-9312
jonh@co.harrison.tx.us

CERTIFICATE OF CONFERENCE

As required by Texas Rule of Appellate Procedure 10.1(a)(5), I certify that I have

conferred, or made a reasonable attempt to confer, with all other parties, which are

listed below, about the merits of this motion with the following results:

Gena Bunn, Attorney for Appellant, does not oppose this Motion.

/s/ Jonathan Hyatt
Jonathan Hyatt

CERTIFICATE OF SERVICE

By affixing my signature below, I, Jonathan Hyatt, hereby certify that a true copy

of Motion for Extension of Time to File Appellee’s Brief has been provided to

Gena Bunn, Attorney for Appellant, on May 1, 2015, by facsimile as provided by

Rule 9.5(b) of the Texas Rules of Appellate Procedure.

/s/ Jonathan Hyatt
Jonathan Hyatt

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