Reginald Reece v. State ( 2015 )

ACCEPTED
06-14-00192-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
5/22/2015 2:38:22 PM
DEBBIE AUTREY
CLERK
NO. 06-14-00192-CR
FILED IN
REGINALD REECE, § 6th COURT
ON APPEAL OF APPEALS
FROM THE
TEXARKANA, TEXAS
Appellant §
5/22/2015 2:38:22 PM
§ 202ND JUDICIAL DISTRICT
DEBBIE AUTREY
VS. § Clerk
§
STATE OF TEXAS, § COURT OF BOWIE COUNY
Appellee § TEXAS
MOTION TO EXTEND TIME FOR FILING STATE’S BRIEF
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW the State of Texas by and through her below named Criminal
District Attorney and pursuant to Texas Rules of Appellate Procedure and hereby
requests a thirty (30) day extension of the time period for the filing of the State’s
Brief and in support of the same should show the Court as follows:
I.
1. This case is pending from the 202nd Judicial District of Bowie County, Texas.
2. The case is styled State of Texas v. Reginald Reece, Cause No. 11F0746-202.
3. Appellant was found guilty to the offense of Theft with Priors and sentenced to
twenty (20) years in the Institutional Division of the Texas Department of Criminal
Justice and $10,000.00 fine.
5. Appellant’s Brief was filed on April 21, 2015 making the State’s Brief originally
due on or about May 21, 2015.
6. The State not previously requested an extension of time for filing a brief.
7. 7. The Brief was not timely prepared in this matter due to the press of the business,
both trial and appellate. Said business includes, but is not limited to, the following
since Appellant’s brief was filed:
 Preparation for the trial and pre-indictment dockets for the 202nd District
Court scheduled for April 27, 2015
 Preparation and attendance at the trial and pre-indictment dockets for the 5th
District Court on May 4, 2015.
 Preparation and attendance at the trial and pre-indictment dockets for the
202nd District Court on May 11, 2015.
 Preparation and attendance at the trial and pre-indictment dockets for the 5th
District Court on May 18, 2015
 Pre-trial conferences and trial preparation for Jury Trial from May 19-21,
2015 in State of Texas v. Antonio Moore, Murder- 14F0611-102, Intoxication
Assault- 14F0612-102.
 Pre-trial conferences and trial preparation on Matthew Schneider, DWI 3rd or
more- 14F0324-202, DWI 3rd or More- 14F0724-202, DWI 3rd or more-
14F0778-202, which was set for trial on May 26, 2015. The case was resolved
by plea agreement at the final pretrial on May 21, 2015.
II.
The State’s attorney has been diligent in pursuing this appeal and is not seeking this
extension for the purpose of delay.
PRAYER
WHEREFORE, on the bases of Rule 73 of the Texas Rules of Appellate Procedure,
the State respectfully requests this Court to grant the Motion for Extension of Time
for the filing of the State’s Brief.
Respectfully submitted,
__/s/ Lauren N. Sutton______
LAUREN N. SUTTON
Texas Bar No. 24079421
601 Main Street
Texarkana, TX 75501
ASSISTANT DISTRICT ATTORNEY
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing Motion to
Extend Time for Filing State’s Brief was forwarded to Mr. Alwin Smith, counsel
for Appellant, on this the 22nd day of May, 2015.
__/s/ Lauren N. Sutton______
LAUREN N. SUTTON