ACCEPTED
05-14-00517-CR
FIFTH COURT OF APPEALS
DALLAS, TEXAS
10/6/2015 3:25:38 PM
LISA MATZ
CLERK
NO. 05-14-00517-CR
ARIANNA LINDSAY § IN THE COURT OF APPEALS
FILED IN
5th COURT OF APPEALS
vs. § FOR THE FIFTH DISTRICT
DALLAS, TEXAS
THE STATE OF TEXAS § 10/6/2015
OF TEXAS AT3:25:38
DALLASPM
LISA MATZ
Clerk
STATE’S SECOND MOTION FOR EXTENSION OF TIME TO FILE
BRIEF
TO THE HONORABLE JUDGES OF SAID COURT:
THE STATE OF TEXAS, by and through the Criminal District Attorney of
Dallas County, respectfully requests that the time for filing the State’s brief be
extended from April 29, 2015 to October 6, 2015. See TEX. R. APP. P. 38.6(d). In
support of this motion, the State would show the following:
Appellant entered a plea of guilty the offense of causing serious bodily injury to
a child. After a punishment hearing, the trial court sentenced appellant to eighteen
years’ imprisonment. Judgment was entered on April 3, 2014. Appellant’s brief was
originally due on October 29, 2014. After requesting and receiving two extensions,
Appellant’s brief was ultimately filed on February 28, 2015. After requesting and
receiving one thirty-day extension, the State’s brief was due, under Rule 38.6(b) of the
Texas Rules of Appellate Procedure, on April 29, 2015. This case will be submitted to
the Court on November 4, 2015.
Good cause justifies the granting of this extension. Due to this attorney’s
existing docket, the State requests an extension of time from April 29, 2015 until
October 6, 2015, in which to file its brief. Counsel has prepared the State’s brief in
this case as expeditiously as possible without sacrificing quality and tenders the brief
for filing with this motion.
WHEREFORE, PREMISES CONSIDERED, the State respectfully requests that
the time for filing its brief be extended until October 6, 2015.
Respectfully submitted,
Susan Hawk Laura Anne Coats
Criminal District Attorney Assistant District Attorney
Dallas County State Bar No. 00790476
Frank Crowley Courts Building
133 N. Riverfront Blvd.,LB19
Dallas, Texas 75207-4399
(214) 653-3625
(214) 653-3643 fax
LAURA.COATS@dallascounty.org
CERTIFICATE OF SERVICE
I hereby certify that a true copy of the foregoing was served on Riann C.
Moore, Counsel for Appellant, Dallas County Public Defender’s Office by email
pursuant to the efiling system on at Riann.Moore@dallascounty.org, on October 6,
2015.
Laura Anne Coats
CERTIFICATE OF WORD COMPLAINCE
I hereby certify that the foregoing motion is 393 words in length according to
Microsoft Word, which was used to prepare the brief. See Tex. R. App. P. 73.3; Tex.
R. App. P. 73.1(f).
__________________________________
LAURA ANNE COATS