Cory Martin Colvin v. State

ACCEPTED 06-14-00163-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 2/24/2015 3:56:25 PM DEBBIE AUTREY CLERK NO. 06-14-00163-CR CORY MARTIN COLVIN § SIXTH COURT FILED IN § 6th COURT OF APPEALS VS. § TEXARKANA, TEXAS OF APPEALS § 2/24/2015 3:56:25 PM THE STATE OF TEXAS § DEBBIEOF STATE AUTREY TEXAS Clerk APPELLEE’S FIRST MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF COMES NOW the State of Texas appellee, and moves this Court pursuant to Tex. R. App. Proc. 10.5 and 38.6 (D) for an extension of thirty (30) day’s or until March 25, 2015, in which to file the appellee’s brief herein. In support, appellee would show the following; 1. Appellant was charged with Aggravated Sexual Assault of a Child in State of Texas v. CORY MARTIN COLVIN, Cause No. 16,601, 115th District Court of Upshur County, Texas. 2. On August 15, 2014, appellant was found guilty and the Jury assessed punishment for Ninety Nine (99) Years confinement in the Institutional Division-TDCJ. 3. Notice of appeal was given on August 15, 2014. 5. The Appellee’s brief is due for filing on February 25, 2015. 6. This is the first request for extension of time. 7. Appellee requests an extension until March 25, 2015. 8. Good cause exists for the granting of the motion. Within the past thirty days counsel for the State has undertaken the following matters: A: Counsel was responsible for completing the brief on Charles McClain which was due on February 11, 2015 in the Twelfth Court of Appeals. Jury Selection in the County Court of Upshur County was set on February 17, 2015. Counsel assisted her coworker in trial in The State of Texas v. Linda Luker in County Court. Counsel has been preparing cases for grand jury on February 25, 2015. Counsel has also been responsible for preparing the response to 15,574-A, Writ of Habeas Corpus on Paden D. Richardson. 9: This motion is not sought for purposes of delay, but so that justice may be done. Therefore, Appellee requests until March 25, 2015, in which to complete her brief. Respectfully submitted, Upshur County Assistant District Attorney Natalie A. Miller 405 N. Titus Gilmer, TX 75644 Tel: (903) 843-5513 Fax: (903) 843-3661 By: /S/ Natalie A. Miller Natalie A. Miller State Bar No. 24079007 CERTIFICATE OF SERVICE A true and correct copy of the foregoing document has been delivered to all counsel of record, on this the 24th day of February, 2015. /S/ Natalie A. Miller Natalie A. Miller