ACCEPTED
06-14-00221-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
7/1/2015 2:58:01 PM
DEBBIE AUTREY
CLERK
CASE NO. 06-14-00221-CR
In The FILED IN
6th COURT OF APPEALS
TEXARKANA, TEXAS
COURT OF APPEALS 7/1/2015 2:58:01 PM
SIXTH DISTRICT OF TEXAS DEBBIE AUTREY
AT TEXARKANA Clerk
BRIAN EUGENE WOODARD, Appellant
VS.
THE STATE OF TEXAS, Appellee
On Appeal from the 354th Judicial District Court
of Hunt County, Texas
Trial Court Cause No. 29,390
Honorable Richard A. Beacom, Jr. Judge Presiding
MOTION FOR EXTENSION OF TIME TO FILE STATE'S BRIEF
NOBLE DAN WALKER, JR.
District Attorney, in and for
Hunt County, Texas
KELI M. AIKEN
Assistant District Attorney
State Bar Number- 24043442
P.O. Box 441
4th Floor, Hunt County Courthouse
Greenville, Texas 75401
Telephone Number- (903) 408-4180
Facsimile Number- (903) 408-4296
kaiken@huntcounty.net
MOTION FOR EXTENSION OF TIME TO FILE STATE'S BRIEF
Comes now, The State of Texas, and files this, her Motion for
Extension of Time to File State's Brief.
I.
The current filing deadline for the State's brief was June 25, 2015.
II.
The State requests a two week extension to file her brief, that is, until
July 10, 2015.
Ill.
The State requests an extension because the case was previously
tried and assigned to a prosecutor who is no longer with our office. We
discovered today that the brief was due last Thursday and we will need a
few days to get the record from the court reporter, review the file and brief
and prepare a response. It is our plan to start working on the appeal
immediately and file it as soon as we can get it finished.
IV.
The State has made no previous requests for extensions to file her
brief.
V.
We attempted to contact Mr. Perry, Appellant's counsel and left a
message for him but were unable to conference with him prior to the filing
of this motion.
VI.
For the reasons stated hereinabove, it is respectfully requested that
this Court grant the State of Texas until July 10, 2015, to file her brief.
Respectfully submitted,
/s/ Keli M. Aiken
Keli M. Aiken
First Assistant District Attorney
Hunt County, Texas
P.O. Box 441
Greenville, Texas 75403-0441
Phone: 903/408-4180
Fax: 903/408-4296
kaiken@huntcounty.net
CERTIFICATE OF CONFERENCE
I certify that I attempted to reach Mr. Perry today, June 29, 2015 on his
office number and also on his cell number. I left him a message on his cell and
stated the reason for my call as well as my return office and cell numbers.
Is/ Keli M. Aiken
Keli M. Aiken
CERTIFICATE OF SERVICE
This is to certify that a true copy of this Motion to Extend Time to File
State's Brief has been faxed to Mr. Perry at 903/886-2043.
/s/ Keli M. Aiken
Keli M. Aiken