Martha Aracely Richter v. State

ACCEPTED
06-15-00126-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
9/24/2015 1:35:49 PM
DEBBIE AUTREY
CLERK
NO. 06-15-00126-CR
MARTHA RICHTER § IN THE COURT FILED
OF APPEALS
IN
§ 6th COURT OF APPEALS
TEXARKANA, TEXAS
V. § FOR THE SIXTH DISTRICT
9/24/2015 1:35:49 PM
§
DEBBIE AUTREY
THE STATE OF TEXAS § OF TEXAS AT TEXARKANA
Clerk
Motion To Extend Time For Filing Appellant's Brief
Appellant, by and through her attorney of record, respectfully requests an extension of
time to file her brief. In support Appellant shows:
Appellant was convicted for the offense of Driving While Intoxicated in Cause No.
14-11631CR in the County Court at Law No. 2 of Ellis County, Texas, before the Honorable
Gene Calvert. The judgment was dated June 30, 2015. Notice of Appeal was filed on July 2,
2015.
The present deadline for filing Appellant's brief is September 25, 2015. Appellant
respectfully requests an extension of time until November 24, 2015. No previous
extension of time has been granted. Counsel has had a heavy caseload within the last few
months requiring her appearance in multiple courts in Ellis County. Preparing the trial
dockets have required the great majority of counsel’s time.
The Reporter’s Record was filed August 4, 2015, in the Tenth Court of Appeals of
Waco, Texas. On this same date, the Tenth Court of Appeals transferred the above cause
to the Sixth District Court of Appeals of Texarkana, Texas. On August 26, 2015, the
certified Clerk’s Record was filed in the Sixth Court of Appeals. The issues in this case
Motion to Extend Time to File Appellant Brief Page 1
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are complex and varied. For these reasons, Appellant’s counsel requests a sixty (60) day
extension in which to file Appellant’s brief.
Additionally, on September 24, 2015, Counsel for Appellant conferred with the
Ellis County District Attorney’s Office, Appellee representing the State of Texas.
Appellee does not oppose this Motion. Appellee does not object to the Court granting
this Motion for the Extension of Time to file the Appellant’s Brief.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests that
the time for filing Appellant's brief be extended to November 24, 2015.
Respectfully submitted,
/s/Julissa Martinez
_________________________________
Julissa Martinez
Attorney for Appellant
STATE BAR NO. 24032580
107 Kaufman St
Waxahachie, TX 75165
972-937-4477
FAX: 972-937-4485
jmmartinez@martinezjustice4all.com
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing motion has been served on the Ellis
County District Attorney's Office, 300 South Jackson St, Waxahachie, TX 75165, by hand-
delivery or by fax on September 24, 2015.
/s/Julissa Martinez
__________________________________
Julissa Martinez
Motion to Extend Time to File Appellant Brief Page 2
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NO. 06-15-00126-CR
MARTHA RICHTER § IN THE COURT OF APPEALS
§
V. § FOR THE SIXTH DISTRICT
§
THE STATE OF TEXAS § OF TEXAS AT TEXARKANA
ORDER ON DEFENDANT’S MOTION FOR SIXTY DAY EXTENSION OF TIME TO
FILE APPELANT’S BRIEF
BE IT REMEMBERED, that on the ______ day of ________________, 2015, came on to be
considered the above and foregoing Motion for Sixty Day Extension of Time to File Appellant’s Brief.
After consideration of the same, it is the opinion of the Court that Defendant's Motion be:
( ) DENIED, in whole to which ruling the Defendant accepts.
( ) GRANTED, and the Deadline for Appellant to File his Brief is November 24, 2015.
( ) GRANTED, __________________________________________________
_____________________________________________________________
_____________________________________________________________
( ) SET FOR HEARING ON THE ______ day of ________________, 2015, at _____
o'clock ____.
SIGNED: ________________, 2015.
______________________________
JUSTICE PRESIDING
Motion to Extend Time to File Appellant Brief Page 3
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