CASE NOS. 06-14-00239-CR In The COURT OF APPEALS SIXTH DISTRICT OF TEXAS AT TEXARKANA
MARK EUGENE ENGLE, Appellant VS. THE STATE OF TEXAS, Appellee On Appeal from the 354th Judicial District Court ofHunt County, Texas Trial Court Cause Nos. 29,110 Honorable Richard A. Beacom, Jr., Judge Presiding

STATE'S SECOND MOTION FOR EXTENSION OF TIMETO FILE STATE'S BRIEF

NOBLE DAN WALKER, JR. DistrictAttorney, in and for Hunt County, Texas STEVE LlLLEY Assistant DistrictAttorney State Bar Number- 24046293 P.O. Box441 4th Floor, Hunt County Courthouse Greenville, Texas 75401 Telephone Number- (903) 408-4180 Facsimile Number- (903) 408-4296 Email: slilley@huntcounty.net ACCEPTED 06-14-00239-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 9/11/2015 3:25:31 PM DEBBIE AUTREY

CLERKSTATE'S SECOND MOTION FOR EXTENSION OF TIME TO FILE STATE'S BRIEF
Comes now, The State ofTexas, and files this, her First Motion for Extension ofTime to File State's Brief. I. The currentfiling deadline forthe State's brief is September 11, 2015. II. The State's briefwas originally due in this case on August 24, 2015. On August26, 2015, a member ofthe DistrictAttorney's Officefiled a first request for extension oftime to file a brief in this case. The extension was requested for a period ofeighteen (18) days from the original due date. The Court granted the extension and the briefwas then due on September 11, 2015. However, the attorney responsible for drafting the brief in this
case (as he tried the case in front ofajury and handled the suppression hearing)was, during this time, in the midst ofa murdertrial entitled The State ofTexas v. Joshua Madison Newkirk, Cause No. 29,984. This trial began on August 24, 2015 and was notfinished until the late evening of September 1, 2015. Earlythe next morning, the same prosecutor leftfor
on a prearranged trip to the State of New Mexico to research background

2information on a capital murder case entitled The State ofTexas v. Kyle Anthony Kauffmann, Cause No. 30,265. The prosecutor returned from the trip at approximately 11 :OOpm on Thursday, September 3rct_ The prosecutor returned to the office on Friday, September4, 2015 to work on a number ofmatters, including this appeal, that had been accumulating for the past several weeks. As the Court is aware, Monday, September 7 was a holiday. With onlythree working days remaining before the briefwas due, the prosecutor has regrettably been unableto completework on the brief. Ill. The State therefore requests an additional threeweeks time to complete its work on the brief. Specifically, the State requests a due date ofOctober 2, 2015. IV. The State has made one previous requests for extensions to file her brief in this case. 

### V.
Forthe reasons stated hereinabove, it is respectfully requested that this Court grantthe State ofTexas until October 2, 2015, to file her brief.

3_/Steve Lilley Assistant DistrictAttorney Hunt County, Texas P.O. Box 441 Greenville, Texas 75403-0441 Phone: 903/408-4180 Fax: 903/408-4296 Email: slilley@huntcounty.net

CERTIFICATE OF CONFERENCE I certifythat I have conferred with Appellant's attorney and he does not object to the requested extension oftime.

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CERTIFICATE OF SERVICE This is to certifythat atrue copy ofthis Motion to Extend Time to File State's Brief has been forwarded to Mr. Jason Duffby placing a copy in his mailbox in the district clerk's office per lo

Steve Lilley 4