ACCEPTED
06-14-00208-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
10/13/2015 12:22:14 PM
DEBBIE AUTREY
CLERK
NO. 06-14-00208-CR
TONY DEWAYNE CRAYTON § IN THE
FILED IN
§ 6th COURT OF APPEALS
v § 6th COURT TEXARKANA, TEXAS
§ 10/13/2015 12:22:14 PM
STATE OF TEXAS § OF APPEALS DEBBIE AUTREY
Clerk
MOTION FOR LEAVE TO FILE APPELLEE’S BRIEF LATE
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes The State of Texas, Appellee in the above styled and numbered cause, and prays
this Court to grant leave to file Appellee’s brief late, pursuant to the Texas Rules of Appellate
Procedure, and for good cause shows the following:
1. This case is on appeal from the 8th Judicial District Court of Hopkins County, Texas.
2. The case below was styled the STATE OF TEXAS vs. TONY DEWAYNE
CRAYTON and numbered as 1323670.
3. The Appellant was convicted and sentenced by the judge to 50 years in the
penitentiary after a trial before the court.
4. The Appellee’s brief was due by midnight on October 12, 2015. Appellee requests
leave to file Appellee’s brief late on October 13, 2015.
6. Appellee’s brief is being filed contemporaneous with the motion.
7. Appellee requests leave due to the following:
i. Appellee’s attorney was involved in preparing and trying State of Texas v.
Franklin Coy Kuhl, Jr., Cause Number 1423952 the week before the brief was due.
This was a serious case wherein the defendant received a life sentence on
Wednesday, October 13, 2015.
ii. Although Appellee’s attorney had previously been working on the brief, in
attempting to finish the brief on Monday, October 12, 2015 (Columbus Day), the
issues and research became more in-depth and he failed to completely finish prior to
the midnight deadline.
WHEREFORE, PREMISES CONSIDERED, Appellee prays that this Court grant leave
to file Appellee’s Brief a few hours late, and for such other and further relief as the Court may deem
appropriate.
Respectfully submitted,
By: //s// Will Ramsay
Will Ramsay
8th Judicial District Attorney
State Bar No. 24039129
P.O. Box 882
110 Main Street
Sulphur Springs, TX 75482
Ph: (903) 885-0640
Fax: (903) 885-0641
wramsay@hopkinscountytx.org
Attorney for Appellee
CERTIFICATE OF SERVICE
I hereby certify that a copy of the above and foregoing MOTION FOR LEAVE TO
FILE APPELLEE’S BRIEF LATE was delivered via email to Martin Braddy, Attorney for
Appellant, on October 13, 2015.
//s//Will Ramsay
WILL RAMSAY—Attorney for the Appellee