ACCEPTED
06-15-00152-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
11/24/2015 11:08:56 AM
DEBBIE AUTREY
CLERK
NO. 06-15-00152-CR
FILED IN
6th COURT OF APPEALS
IN THE COURT OF APPEALS TEXARKANA, TEXAS
SIXTH APPELLATE DISTRICT OF TEXAS 11/24/2015 11:08:56 AM
AT TEXARKANA DEBBIE AUTREY
Clerk
ANGELINE BETH VILLINES
Appellant
v.
THE STATE OF TEXAS
Appellee
TRIAL COURT CASE NUMBER 25003
MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF
MICHAEL D. MOSHER
State Bar No. 14580100
THE MOSHER JUSTICE CENTER
50 NORTH MAIN
PARIS, TEXAS 75460
(903) 785-4721 TELEPHONE
(903) 785-5319 FAX
ORAL ARGUMENT REQUESTED
Pursuant to Appellate Rule 10.5(b), the Appellant, Angela Villines, files this request for a
45-day extension of time to file Appellant’s Brief as follows.
The Appellant’s Brief is currently due on November 30, 2015. Appellant requests a
45-day extension to file her brief, which would make the new due date January 14, 2015. This is
the first extension requested by Appellant for filing this brief. Appellant requests this additional
time to file her brief because counsel has been unable to adequately prepare her brief because her
counsel did not receive the court reporter’s transcript until November 23, 2015 and due to other
obligations, including the following:
1. Preparation for civil trial on October 26, 2015 through November 5, 2015in case
styled In the Interest of Emma Grace Griffith pending in Cause Number 325-550106-14 in the
325th District Court, Tarrant County, Texas.
2. Preparation and attendance at Pre-Trial on November 12, 2015 in case styled
Richard Finley Vs. Sharron L. Cox and Moss & Cox pending in Cause Number 81657 in the
62nd District Court, Lamar County, Texas.
3. Preparation and attendance at Pre-Trial on November 13, 2015 in case styled
Teresa Musick Vs. Harold Ford pending in Cause Number 81376 in the 6th District Court, Lamar
County, Texas.
4. Preparation and attendance at criminal plea bargain docket on November 16, 2015
in case styled The State of Texas Vs. Jonathan Sims pending in Cause Number 26339 in the 6th
District Court, Lamar County, Texas.
5. Preparation and attendance at criminal plea bargain docket on November 16, 2015
in case styled The State of Texas Vs. Talisha Moore pending in Cause Number 26407 in the 6th
District Court, Lamar County, Texas.
6. Preparation and attendance at criminal plea bargain docket on November 16, 2015
in case styled The State of Texas Vs. Cornisha Brown pending in Cause Number 26390 in the 6th
District Court, Lamar County, Texas.
7. Preparation and attendance at hearing for Motion for New Trial on November 16,
2015 in case styled Jeanine Lauren Vs. Gary Grass, Et Al pending in Cause Number Cv03290 in
the 102nd District Court, Red River County, Texas.
8. Preparation and attendance at hearing for Motion for New Trial on November 16,
2015 in case styled Jeanine Lauren Vs. Gary Grass pending in Cause Number Cv03291 in the
102nd District Court, Red River County, Texas.
9. Preparation and attendance at criminal pre-trial on November 17, 2015 in case
styled The State of Texas Vs. Taylor Anderson pending in Cause Number 26263 in the 6th
District Court, Lamar County, Texas.
10. Preparation and attendance at criminal pre-trial on November 17, 2015 in case
styled The State of Texas Vs. Taylor Anderson pending in Cause Number 26263 & 26264 in the
6th District Court, Lamar County, Texas.
11. Preparation and attendance at criminal pre-trial on November 17, 2015 in case
styled The State of Texas Vs. Emily Sharrock pending in Cause Number 26380 in the 6th District
Court, Lamar County, Texas.
12. Preparation and attendance at criminal trial on November 17, 2015 in case styled
The State of Texas Vs. Stephanie Blalock pending in Cause Number 25815 in the 6th District
Court, Lamar County, Texas.
13. Preparation and attendance at criminal trial on November 17, 2015 in case styled
The State of Texas Vs. Clemet Wilburn pending in Cause Number 23348 in the 6th District
Court, Lamar County, Texas.
14. Preparation and attendance at criminal trial on November 20, 2015 in case styled
The State of Texas Vs. Sherena Emeyabbi pending in Cause Number 25892 & 25893 in the 6th
District Court, Lamar County, Texas.
15. Preparation and attendance at criminal trial on November 20, 2015 in case styled
The State of Texas Vs. Tonya Scott pending in Cause Number 23673 in the 6th District Court,
Lamar County, Texas.
16 Preparation and attendance at a deposition on November 24, 2015 in case styled
Julie Hecht vs. Harold Been pending in Index No. 22081/2012E in the Supreme Court of the
State of New York, County of Bronx.
17. Appellant’s counsel’s office was closed for the Thanksgiving holidays November
26, 2015 through November 27, 2015.
18. Preparation and attendance at hearing for temporary orders on November 30,
2015 in case styled In the Interest of EG and NJG, Children pending in Cause Number 78307 in
the County Court at Law, Lamar County, Texas.
19. Counsel’s attorney, Michael D. Mosher, has a vacation scheduled for Istanbul and
will be on vacation from December 3-8, 2015.
20. Preparation and attendance at a deposition on December 11, 2015 in case styled
In the Interest of Clint Wayne Freeman II and Wyhtt Freeman pending in Cause Number CV-
02143 in the 6th District Court, Red River County, Texas.
21. Appellant’s counsel’s office will be closed for the Christmas holidays December
24, 2015 through December 25, 2015.
This request is not made for purpose of delay, but to permit Appellant sufficient time to
prepare his brief.
PRAYER
The Appellant respectfully requests that the Court grant a 45-day extension of time to file
his brief, extending the date to file the brief from November 30, 2015 until January 14, 2016.
Respectfully submitted,
THE LAW OFFICE OF
MICHAEL D. MOSHER
/s/ Michael D, Mosher
MICHAEL D. MOSHER
STATE BAR NO. 14580100
THE MOSHER JUSTICE CENTER
50 NORTH MAIN
PARIS, TEXAS 75460
(903) 785-4721 TELEPHONE
(903) 785-5319 FAX
E-MAIL: mdm@mosherjusticectr.com
DATE: November 24, 2015
CERTIFICATE OF SERVICE
On November 24, 2015 a true and correct copy of the foregoing document was delivered
to Mr. Gary Young, County Attorney, in accordance with the rules of this court.
/s/ Michael D. Mosher
Michael D. Mosher