ACCEPTED
06-14-00232-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
5/13/2015 5:23:52 PM
DEBBIE AUTREY
CLERK
IN THE COURT OF APPEALS FOR THE
SIXTH DISTRICT OF TEXAS AT TEXARKANA
FILED IN
6th COURT OF APPEALS
CHRISTI BETH PERRIN, § TEXARKANA, TEXAS
APPELLANT § 5/13/2015 5:23:52 PM
§ No. 06-14-00232-CR
DEBBIE AUTREY
v. § Clerk
§
THE STATE OF TEXAS, §
APPELLEE §
STATE’S FIRST MOTION FOR EXTENSION OF TIME
TO FILE STATE’S BRIEF
COMES NOW, the State of Texas, by and through the Criminal District
Attorney of Collin County, Greg Willis, and tenders, pursuant to Texas Rules of
Appellate Procedure 10.5(b) and 38.6(d), this motion for an extension of time to
file the State’s brief. In support of this motion, the State would show the following:
I.
The Court below is County Court at Law Four of Collin County, Texas. The
case is styled State of Texas v. Christi Beth Perrin, cause number 004-82924-2014.
II.
Appellee was convicted by a jury of driving while intoxicated and sentenced
to six days in the county jail.
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III.
The State’s brief is due on May 13, 2015. The State has not previously
requested an extension of time. The case is not yet set for submission. The State is
requesting this extension so that it might adequately address the issues at hand. The
extension is not requested for the purpose of an improper delay.
IV.
The State alleges good cause exists for the extension due to the
undersigned’s schedule. The undersigned has tried two jury trials in the last ten
days and has an active trial docket with several trials scheduled in the next month.
The undersigned has also recently been tasked with new duties within the office,
which have required training.
WHEREFORE, premises considered, the State respectfully requests that the
Court grant the State’s motion to extend the time to file its brief for thirty days,
until June 13, 2015.
Respectfully submitted,
GREG WILLIS
Criminal District Attorney
Collin County, Texas
JOHN R. ROLATER, JR.
Assistant Criminal District Attorney
Chief of the Appellate Division
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/s/ Erik F. Gierczyk
ERIK F. GIERCZYK
Assistant Criminal District Attorney
2100 Bloomdale Rd., Ste. 200
McKinney, Texas 75071
State Bar No. 24082333
(972) 548-3657
FAX (214) 491-4860
egierczyk@co.collin.tx.us
CERTIFICATE OF SERVICE
A true copy of the State’s First Motion for Extension of Time to File State’s
Brief has been electronically served on counsel for Appellant, John Schomburger,
and a courtesy copy emailed to jschomburger@gmail.com, on this, the 13th day
of May, 2015.
/s/ Erik F. Gierczyk
Erik F. Gierczyk
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