David Sylvester Chambers v. State

ACCEPTED 06-15-00122-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 11/18/2015 1:46:09 PM DEBBIE AUTREY CLERK CASE NO. 06-15-00122-CR DAVID SYLVESTER CHAMBERS § IN THE FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS VS. § SIXTH COURT OF APPEALS 11/18/2015 1:46:09 PM DEBBIE AUTREY Clerk THE STATE OF TEXAS § OF TEXAS STATE’S FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF COMES NOW, the State of Texas, by and through its Assistant District Attorney, Maritza Sifuentez, and files this Motion for Extension of Time to File State’s Brief. The State would show in support of her action that: 1. The case is styled David Sylvester Chambers v. The State of Texas, cause no. 13-02053-CRF-272 out of the 272nd District Court, Brazos County, Texas. 2. Notice of Appeal was filed in the Court of Appeals on June 12, 2015. 3. The clerk’s record was filed on July 22, 2015; The reporter’s record was filed on August 20, 2015. 4. Appellant’s brief was filed October 19, 2015. 5. The deadline for filing State’s Brief is November 18, 2015. 6. The length of time requested is until December 4, 2015. 7. This is the State’s first request for an extension. 8. And as good cause the State’s attorney, Maritza Sifuentez, would show this Court that this request is made because of the following:  The State’s attorney assisted the District Attorney and First Assistant District Attorney in jury selection, pretrial hearings, and capital murder jury trial styled The State of Texas v. Gabriel Paul Hall cause no. 11-06185-CRF-272 out of the 272nd District Court, Brazos County, Texas from September 8, 2015 to October 7, 2015; the State’s attorney has assisted the District Attorney and First Assistant District Attorney with several post-trial matters in the same cause.  The Brazos County District Attorney’s Office was required to relocate their offices during the week of November 9, 2015.  The State’s attorney is scheduled to be out of the office between November 25, 2015 through December 1, 2015.  In addition, the State’s attorney has worked on the following cases, appeals, contested motions, or writs recently: o Tyrone Calvin Smith, III v. The State of Texas, case no. 10- 14- 00192-CR filed October 29, 2015. This request is not made for purposes of delay but so that justice may be served. Respectfully submitted, /s/ Maritza Sifuentez Maritza Sifuentez Assistant District Attorney Brazos County, Texas 300 East 26th Street, Suite 310 Bryan, Texas 77803 (979) 361-4320 misfuentez@brazoscountytx.gov State Bar No. 24082124 CERTIFICATE OF SERVICE I do hereby certify that a true and correct copy of the above and foregoing State’s Motion for Extension of Time to File Brief was served electronically to Rick Wetzel, attorney for Appellant, at wetzel_law@1411west.com on this the 18th day of November, 2015. /s/ Maritza Sifuentez Maritza Sifuentez