Sonya Kay Hargett v. State ( 2015 )

ACCEPTED
06-15-00022-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
7/1/2015 4:17:21 PM
DEBBIE AUTREY
CLERK
APPEAL NO. 06-15-00022-CR
SONYA KAY HARGETT § IN THE COURT OF APPEALS
FILED IN
6th COURT OF APPEALS
§ TEXARKANA, TEXAS
V. § SIXTH DISTRICT OF TEXAS
7/1/2015 4:17:21 PM
§ DEBBIE AUTREY
STATE OF TEXAS § TEXARKANA, ClerkTEXAS
MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF
TO THE HONORABLE JUSTICES OF THE SIXTH COURT OF APPEALS:
COMES NOW, Jonathan Hyatt, and files his Motion for Extension of Time
to File Appellee’s Brief, pursuant to Rules 9 and 10 of the Texas Rules of
Appellate Procedure, and in support thereof, would show the Court the following:
I.
The Deadline for filing Appellee’s Brief is July 6, 2015.
II.
The length of the extension sought is 30 days.
III.
Appellee relies on the following facts to reasonably explain said request for an
extension:
A. Collateral duties within the District Attorney’s Office require that
counsel prepare for a jury trial with jury selection to commence on the
due date of the Appellee Brief. Said case is State v. Victor Dunn, 2014-
0838, Harrison County Court at Law.
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B. Additional staff at the District Attorney’s office is participating in a
Capital Murder case set to begin on the due date of Appellee’s brief.
Incidentally, the Attorney for Appellant is participating in that case as
well.
IV.
This is the first request for an extension to file Appellee’s Brief.
Wherefore, premises considered, undersigned counsel prays for this Court to
extend the time for filing Appellee brief until August 5, 2015, which is thirty days
from the current deadline.
Respectfully Submitted,
/s/ Jonathan Hyatt
Jonathan Hyatt
State Bar No. 24072161
ATTORNEY FOR APPELLEE
Harrison County District Attorney’s Office
P.O. Box 776
Marshall, Texas 75671
Telephone No. (903) 935-8408
Facsimile No. (903) 938-9312
jonh@co.harrison.tx.us
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CERTIFICATE OF CONFERENCE
As required by Texas Rule of Appellate Procedure 10.1(a)(5), I certify that I have
conferred, or made a reasonable attempt to confer, with all other parties, which are
listed below, about the merits of this motion with the following results:
Jason Cassel, Attorney for Appellant, does not oppose this Motion.
/s/ Jonathan Hyatt
Jonathan Hyatt
CERTIFICATE OF SERVICE
By affixing my signature below, I, Jonathan Hyatt, hereby certify that a true copy
of Motion for Extension of Time to File Appellee’s Brief has been provided to
Jason Cassel, Attorney for Appellant, on July 1, 2015, by facsimile as provided by
Rule 9.5(b) of the Texas Rules of Appellate Procedure.
/s/ Jonathan Hyatt
Jonathan Hyatt
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