ACCEPTED
06-15-00037-cr
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
6/24/2015 10:06:34 AM
DEBBIE AUTREY
CLERK
NO. 06-15-00037-CR
______________________________________________________________________________
FILED IN
6th COURT OF APPEALS
In the Sixth Court of Appeals TEXARKANA, TEXAS
Texarkana, Texas 6/24/2015 10:06:34 AM
DEBBIE AUTREY
______________________________________________________________________________
Clerk
THE STATE OF TEXAS, Appellant
V.
ERICA LYNN FULLER, Appellee
______________________________________________________________________________
On Appeal from the 6th Judicial District Court
Lamar County, Texas; Trial Court Cause No. 25545;
Honorable Eric Clifford, Judge
______________________________________________________________________________
FIRST UNOPPOSED MOTION TO EXTEND TIME
FOR FILING BRIEF OF ERICA LYNN FULLER
______________________________________________________________________________
TO THE HONORABLE COURT OF APPEALS:
Appellee, Erica Lynn Fuller, in the above styled and numbered cause, hereby moves the
Court pursuant to Rule 38.6(d), Texas Rules of Appellate Procedure, for an extension of time to file
her brief. As grounds for such extension the Appellees would show unto the Court the following:
I.
Appellee’s brief is currently due on July 6, 2015.
II.
Due to other commitments counsel for Appellee has been unable to devote adequate time to
the completion of research and finalization of the brief in this case. Some of the other obligations
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of counsel during this time were as follows:
1. A previously schedlued vacation during the week of June 9, 2015;
2. Several contested non-jury matters;
3. Representation of a licensed nurse before the Texas Board of Nursing; and
4. Counsel was also involved in numerous other settings during this time.
IV.
Due to the above matters and many others, counsel for Appellee has been unable to devote
sufficient time to the completion of the brief in this case by July 6, 2015.
V.
The undersigned counsel has conferred with counsel for Appellant, who indicates that the
relief sought in this motion is not opposed.
Therefore, Appellee would request an extension of thirty (30) days in which to file her brief.
The requested extension is not requested for delay but that justice be served.
WHEREFORE, PREMISES CONSIDERED, Appellee, Erica Lynn Fuller, prays that the time
for filing their brief be extended thirty (30)) days until August 5, 2015.
THE MOORE LAW FIRM, L.L.P.
BY: __/s/ James R. Rodgers___
James R. Rodgers
State License #17136300
100 N. Main Street
Paris, Texas 75460
Telephone 903/784-4393
Facsimile 903/783-0042
ATTORNEY FOR APPELLEE, ERICA
LYNN FULLER
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CERTIFICATE OF SERVICE
I certify that a true copy of the above document was delivered to all attorneys of
record/parties, in accordance with the Texas Rules of Appellate Procedure this 24th day of June,
2015.
/s/ James R. Rodgers
James R. Rodgers
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