Tonya Ann Rodriguez v. State

ACCEPTED 06-14-00190-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 6/1/2015 4:58:15 PM DEBBIE AUTREY CLERK CASE NOS. 06-14-00190-CR In The FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS COURT OF APPEALS 6/1/2015 4:58:15 PM SIXTH DISTRICT OF TEXAS DEBBIE AUTREY AT TEXARKANA Clerk TONYA ANN RODRIGUEZ, Appellant VS. THE STATE OF TEXAS, Appellee On Appeal from the 354th Judicial District Court ofHuntCoun~,Texas Trial Court Cause Nos. 29,230 Honorable Richard A. Beacom, Jr., Judge Presiding STATE'S SECOND MOTION FOR EXTENSION OF TIME TO FILE STATE'S BRIEF NOBLE DAN WALKER, JR. District Attorney, in and for Hunt County, Texas STEVE LILLEY Assistant District Attorney State Bar Number- 24046293 P.O. Box 441 4th Floor, Hunt County Courthouse Greenville, Texas 75401 ------------------Ielepbone-Number--=-~9031-408~4-1-80--­ Facsimile Number- (903) 408-4296 Email: slilley@huntcounty.net STATE'S SECOND MOTION FOR EXTENSION OF TIME TO FILE STATE'S BRIEF Comes now, The State of Texas, and files this, her First Motion for Extension of Time to File State's Brief. I. The current filing deadline for the State's brief is June 1, 2015. II. The State requests this extension of time to her file her brief due to the fact that the appellate attorney has not yet completed his work on the brief. Between May 1 and June 1, 2015, the attorney responsible for the brief in this case worked to complete the appeal brief in The State of Texas v. Tyrone Denard Anderson, Cause No. 06-14-00074-CR, on May 8, 2015. The same attorney completed findings of fact and conclusions of law for the trial court's approval and submission to the Court of Criminal Appeals in The State of Texas v. Willie Doss, Writ No. 82,858-01, on or about May 15, 2015. The attorney also began work on the appeal brief in The State of Texas v. Mark Anthony Young, Cause No. 06-14-00086-CR and later filed a request for clarification on May 18, 2015. In addition, the same attorney _ _ _ _bas_be_en_making_finaLpreparations_for_jur:y_triaiJo_begin_Ju ne-8,-20-1-5-i 1 " 1 - - - - The State of Texas v. Joshua Madison Newkirk, Cause No. 29,868, a 2 murder case with over thirty persons under subpoena by the State .. Ill. The State believes that it can complete its brief in this case with an extension to July 1, 2015, after the completion of the aforesaid murder trial. The State therefore requests an extension until that date. IV. This is the State's first request for an extension. V. For the reasons stated hereinabove, it is respectfully requested that this Court grant the State of Texas until July 1, 2015, to file her brief. eve Lilley Assistant District Attorney Hunt County, Texas P.O. Box 441 Greenville, Texas 75403-0441 Phone: 903/408-4180 Fax: 903/408-4296 Email: slilley@huntcounty.net 3 CERTIFICATE OF SERVICE This is to certify that a true copy of th)9 Motion to Extend Time to File State's Brief has been forwarded to Mr. FraiJI'k L0'1Q-15 facsimile. J)rtf - Steve Lilley 4