State v. Erica Lynn Fuller ( 2015 )

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 Page -1- 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 Page -2- 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 Page -3-