Zackery Jamarcier Summage v. State

ACCEPTED 06-14-00210-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS 4/1/2015 6:45:05 PM

DEBBIE AUTREY

CLERK

No. 06-14- 00210 - CR

FILED IN 6th COURT OF APPEALS

ZACKERY SUMMAGE § TEXARKANA, TEXAS

SIXTH COURT § 4/1/2015 6:45:05 PM § DEBBIE AUTREY

VS. § OF APPEALS Clerk

§ §

THE STATE OF TEXAS § STATE OF TEXAS

§

APPELLEE’S FIRST MOTION FOR EXTENSION OF TIME TO FILE

APPELLEE’S BRIEF Harrison County District Attorney, Appellee moves this Court pursuant to Tex. R. App. Proc. 10.5 and 38.6(D) for an extension of thirty (30) days or until May 3rd, 2015, in which to file the Appellee’s brief. In support, the Appellee would show the following:

1. The Appellant’s brief was filed on March 4th, 2015.

2. Appellee’s brief is due for filing on April 3rd, 2015.

3. This is the first request for extension of time.

4. Good cause exists for the granting of this motion. Within the past thirty days counsel for

Appellee has undertaken the following matters in addition to his daily docket: A. In March counsel had to prepare and present 40 cases to the Grand Jury; B. Counsel has to prepare briefs in Smith v. State, Cause No. 06-14-00102-CR; Bledsoe

v. State, Cause No. 06-14-00138-CR and Olsen v. State, Cause No. 06-14-001193- CR.

C. Counsel has had to research and render advice on several potential litigation matters to the County Commissioners Court.

D. This motion is not sought for purposes of delay, but so that justice may be done. Wherefore, Appellant requests until May 3rd, 2015, in which to complete his brief.

Respectfully submitted, /S/ Timothy J. Cariker ____________________________ Timothy J. Cariker State Bar No. 24009942 P.O. Box 776 Marshall, Texas 75671 Telephone: 903-935-8408 Fax: 903-938-9312 [email protected] ATTORNEY FOR APPELLEE HARRISON COUNTY DISTICT ATTORNEYS OFFICE

CERTIFICATION OF SERVICE

I certify that a true and correct copy of the Appellee’s First Motion for Extension of Time to File Appellee’s Brief has been delivered to the Appellant’s Attorney on Appeal. .

04/01/2015 /S/ Timothy J. Cariker Dated_____________________________ ___________________________________

Timothy J. Cariker State Bar No. 24009942 P.O. Box 776 Marshall, Texas 75671 Telephone: 903-935-8408 Fax: 903-938-9312 [email protected]