State v. Rosa Elena Arizmendi

ACCEPTED 07-15-00238-CR SEVENTH COURT OF APPEALS AMARILLO, TEXAS 11/10/2015 3:55:26 AM Vivian Long, Clerk NO. 07-15-00238-CR STATE OF TEXAS § IN THE FILED IN § 7th COURT OF APPEALS VS. § SEVENTH COURT AMARILLO, TEXAS § 11/10/2015 3:55:26 AM ROSA ELENA ARIZMENDI § OF APPEALS VIVIAN LONG CLERK MOTION TO EXTEND TIME TO FILE APPELLEE'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: Now comes Rosa Elena Arizmendi, Appellee in the above styled and numbered cause, and moves this Court to grant an extension of time to file Appellee’s Brief, pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good cause shows the following: 1. This case is on the State’s appeal from the 108TH Judicial District Court in and for Potter County, Texas. 2. The case below was styled the STATE OF TEXAS ROSA ELENA ARIZMENDI, and numbered 68589E. 3. Appellee was convicted of Possession of a Controlled Substance, Penalty Group 1, with Intent to Deliver, >400g. 4. Appellee was assessed a sentence of twenty-five (25) years on April 28, 2015. 5. Appellee filed her Motion for New Trial and Motion In Arrest of Judgment on May 15, 2015. The Order Granting New Trial was filed June 16, 2015. 6. Notice of appeal was given by the State on June 22, 2015. 7. Appellant’s Brief was filed on September 8, 2015, and Appellee’s Brief is due on October 28, 2015, after previously granted extension. 8. Appellee was previously granted a second extension of time 10 days from the date that Appellee’s Brief was to be filed; the Court granted the requested extension of 10 days, making the date for filing November 9, 2015. 9. Appellee is currently incarcerated on this charge. 10. Appellee relies on the following facts as good cause for the requested extension: Counsel for Appellee has been unable to upload Appellee’s Brief prior to the 11:59p.m. November 9, 2015, deadline. 11. There have been two previous extensions totaling 30 days granted. 12. Appellee is requesting an extension of approximately four to five hours, bringing the date for filing of Appellee’s brief November 10, 2015. 12. This Motion is not brought for purposes of delay, but so that justice may be done. WHEREFORE, PREMISES CONSIDERED, Appellee prays that this Court grant this Motion To Extend Time to File Appellee's Brief, and for such other and further relief as the Court may deem appropriate. Respectfully submitted, DIANNA L. McCOY Attorney at Law 112 S.W. 8th, Ste. 540 Amarillo, Texas 79101 Tel: 806 373 4025 Fax: 806 350 5414 dianna.mccoy@gmail.com By: /s/ Dianna L. McCoy DIANNA L. McCOY State Bar No. 24026865 Attorney for Rosa Elena Arizmendi CERTIFICATE OF SERVICE This is to certify that on November 10, 2015, a true and correct copy of the above and foregoing document was served on the 47TH Judicial District Attorney’s Office for Appellant the State of Texas, 501 S. Fillmore Street, Suite 5A Amarillo, Texas 79101, by electronic service via efile.txcourts.gov /s/ Dianna L. McCoy DIANNA L. McCOY