ACCEPTED
06-14-00219-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
5/1/2015 5:31:48 PM
DEBBIE AUTREY
CLERK
APPEAL NO. 06-14-00219-CR
DAMION DEWAYNE WILLIAMS § IN THE COURT OF APPEALS
FILED IN
6th COURT OF APPEALS
§ TEXARKANA, TEXAS
V. § SIXTH DISTRICT OF TEXAS
5/1/2015 5:31:48 PM
§ DEBBIE AUTREY
STATE OF TEXAS § TEXARKANA, ClerkTEXAS
MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF
TO THE HONORABLE JUSTICES OF THE SIXTH COURT OF APPEALS:
COMES NOW, Jonathan Hyatt, and files his Motion for Extension of Time
to File Appellee’s Brief, pursuant to Rules 9 and 10 of the Texas Rules of
Appellate Procedure, and in support thereof, would show the Court the following:
I.
The Deadline for filing Appellee’s Brief is May 7, 2015.
II.
The length of the extension sought is 30 days.
III.
Appellee relies on the following facts to reasonably explain said request for an
extension:
A. Due to staff changes within the Harrison County District Attorney’s
office, namely that the former chief appellate attorney accepted
employment in a neighboring county, the appeal workload has shifted to
other members of the District Attorney’s Office that have numerous
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collateral duties. In the time requested for said extension, the new
appellate attorney for the County will have begun employment.
B. Counsel will be second chairing a jury trial beginning May 4, 2015 in the
Harrison County Court at Law in State v. Amy Anderson, Cause Number
2014-0915, and preparation for the jury trial precludes Counsel from
adequately writing the Appellee Brief.
C. Counsel presently has another appeal brief due on May 4, 2015 in the
Sixth Court of Appeals of Texas in Jamie Lee Bledsoe v. State, Appellate
Case Number 06-14-00138-CR.
IV.
This is the first request for an extension to file Appellee’s Brief.
Wherefore, premises considered, undersigned counsel prays for this Court to
extend the time for filing Appellee brief until June 6, 2015, which is thirty days
from the current deadline.
Respectfully Submitted,
/s/ Jonathan Hyatt
Jonathan Hyatt
State Bar No. 24072161
ATTORNEY FOR APPELLEE
Harrison County District Attorney’s Office
P.O. Box 776
Marshall, Texas 75671
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Telephone No. (903) 935-8408
Facsimile No. (903) 938-9312
jonh@co.harrison.tx.us
CERTIFICATE OF CONFERENCE
As required by Texas Rule of Appellate Procedure 10.1(a)(5), I certify that I have
conferred, or made a reasonable attempt to confer, with all other parties, which are
listed below, about the merits of this motion with the following results:
Gena Bunn, Attorney for Appellant, does not oppose this Motion.
/s/ Jonathan Hyatt
Jonathan Hyatt
CERTIFICATE OF SERVICE
By affixing my signature below, I, Jonathan Hyatt, hereby certify that a true copy
of Motion for Extension of Time to File Appellee’s Brief has been provided to
Gena Bunn, Attorney for Appellant, on May 1, 2015, by facsimile as provided by
Rule 9.5(b) of the Texas Rules of Appellate Procedure.
/s/ Jonathan Hyatt
Jonathan Hyatt
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