ACCEPTED
06-14-00239-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
9/11/2015 3:25:31 PM
DEBBIE AUTREY
CLERK
CASE NOS. 06-14-00239-CR
FILED IN
In The 6th COURT OF APPEALS
TEXARKANA, TEXAS
9/11/2015 3:25:31 PM
COURT OF APPEALS
DEBBIE AUTREY
SIXTH DISTRICT OF TEXAS Clerk
AT TEXARKANA
MARK EUGENE ENGLE, Appellant
VS.
THE STATE OF TEXAS, Appellee
On Appeal from the 354th Judicial District Court
of Hunt County, Texas
Trial Court Cause Nos. 29,110
Honorable Richard A. Beacom, Jr., Judge Presiding
STATE'S SECOND MOTION FOR EXTENSION OF TIME TO FILE
STATE'S BRIEF
NOBLE DAN WALKER, JR.
District Attorney, in and for
Hunt County, Texas
STEVE Ll LLEY
Assistant District Attorney
State Bar Number- 24046293
P.O. Box 441
4th Floor, Hunt County Courthouse
Greenville, Texas 75401
Telephone Number- (903) 408-4180
Facsimile Number- (903) 408-4296
Email: slilley@huntcounty.net
STATE'S SECOND MOTION FOR EXTENSION OF TIME TO FILE
STATE'S BRIEF
Comes now, The State of Texas, and files this, her First Motion for
Extension of Time to File State's Brief.
I.
The current filing deadline for the State's brief is September 11,
2015.
II.
The State's brief was originally due in this case on August 24, 2015.
On August 26, 2015, a member of the District Attorney's Office filed a first
request for extension of time to file a brief in this case. The extension was
requested for a period of eighteen (18) days from the original due date.
The Court granted the extension and the brief was then due on September
11, 2015. However, the attorney responsible for drafting the brief in this
case (as he tried the case in front of a jury and handled the suppression
hearing) was, during this time, in the midst of a murder trial entitled The
State of Texas v. Joshua Madison Newkirk, Cause No. 29,984. This trial
began on August 24, 2015 and was not finished until the late evening of
September 1, 2015. Early the next morning, the same prosecutor left for
on a prearranged trip to the State of New Mexico to research background
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information on a capital murder case entitled The State of Texas v. Kyle
Anthony Kauffmann, Cause No. 30,265. The prosecutor returned from the
trip at approximately 11 :OOpm on Thursday, September 3rct_ The
prosecutor returned to the office on Friday, September 4, 2015 to work on
a number of matters, including this appeal, that had been accumulating for
the past several weeks. As the Court is aware, Monday, September 7 was
a holiday. With only three working days remaining before the brief was
due, the prosecutor has regrettably been unable to complete work on the
brief.
Ill.
The State therefore requests an additional three weeks time to
complete its work on the brief. Specifically, the State requests a due date
of October 2, 2015.
IV.
The State has made one previous requests for extensions to file her
brief in this case.
V.
For the reasons stated hereinabove, it is respectfully requested that
this Court grant the State of Texas until October 2, 2015, to file her brief.
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_/Steve Lilley
Assistant District Attorney
Hunt County, Texas
P.O. Box 441
Greenville, Texas 75403-0441
Phone: 903/408-4180
Fax: 903/408-4296
Email: slilley@huntcounty.net
CERTIFICATE OF CONFERENCE
I certify that I have conferred with Appellant's attorney and he does
not object to the requested extension of time.
~;t~
~eLilley
CERTIFICATE OF SERVICE
This is to certify that a true copy of this Motion to Extend Time to File
State's Brief has been forwarded to Mr. Jason Duff by placing a copy in his
mailbox in the district clerk's office per lo
Steve Lilley
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Mark Eugene Engle v. State
Combined Opinion