ACCEPTED
06-15-00152-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
12/29/2015 3:51:51 PM
DEBBIE AUTREY
CLERK
NO. 06-15-00152-CR
FILED IN
6th COURT OF APPEALS
IN THE COURT OF APPEALS TEXARKANA, TEXAS
SIXTH APPELLATE DISTRICT OF TEXAS 12/30/2015 8:15:00 AM
AT TEXARKANA DEBBIE AUTREY
Clerk
ANGELINE BETH VILLINES
Appellant
v.
THE STATE OF TEXAS
Appellee
TRIAL COURT CASE NUMBER 25003
SECOND MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF
MICHAEL D. MOSHER
State Bar No. 14580100
THE MOSHER JUSTICE CENTER
50 NORTH MAIN
PARIS, TEXAS 75460
(903) 785-4721 TELEPHONE
(903) 785-5319 FAX
ORAL ARGUMENT REQUESTED
Pursuant to Appellate Rule 10.5(b), the Appellant, Angela Villines, files this request for a
14-day extension of time to file Appellant’s Brief as follows.
The Appellant’s Brief is currently due on December 30, 2015. Appellant requests a
14-day extension to file her brief, which would make the new due date January 13, 2015. This is
the second extension requested by Appellant for filing this brief. Appellant requests this
additional time to file her brief because the attorney assisting counsel in preparing the brief has
had surgery on his leg on December 9, 2015 and has missed time in the office due to the surgery
and physical therapy and counsel has been unable to adequately prepare her brief due to other
obligations, including the following:
1. Counsel’s attorney, Michael D. Mosher, was on a scheduled vacation in Istanbul
from December 3-8, 2015.
2. Preparation and attendance at a deposition on December 11, 2015 in case styled
In the Interest of Clint Wayne Freeman II and Wyhtt Freeman pending in Cause Number CV-
02143 in the 6th District Court, Red River County, Texas.
3. Appellant’s counsel’s office was closed for the Christmas holidays December 24,
2015 through December 27, 2015.
4. Appellant’s counsel’s office will be closed New Years Day January 1, 2015.
5. Preparation and attendance at mediation on January 7, 2016 in case styled
Richard Finley Vs. Sharron L. Cox, Et Al pending in Cause Number 81657 in the 62nd District
Court, Lamar Co., Texas.
This request is not made for purpose of delay, but to permit Appellant sufficient time to
prepare his brief.
PRAYER
The Appellant respectfully requests that the Court grant a 14-day extension of time to file
his brief, extending the date to file the brief from December 30, 2015 until January 14, 2016.
Respectfully submitted,
THE LAW OFFICE OF
MICHAEL D. MOSHER
/s/ Michael D, Mosher
MICHAEL D. MOSHER
STATE BAR NO. 14580100
THE MOSHER JUSTICE CENTER
50 NORTH MAIN
PARIS, TEXAS 75460
(903) 785-4721 TELEPHONE
(903) 785-5319 FAX
E-MAIL: mdm@mosherjusticectr.com
DATE: December 29, 2015
Angela Beth Villines v. State
Combined Opinion