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 

of Hunt County, Texas 

Trial Court Cause Nos. 29,110 

Honorable Richard A. Beacom, Jr., Judge Presiding 

STATE'S SECOND MOTION FOR EXTENSION OF TIME TO FILE 

STATE'S BRIEF 

NOBLE DAN WALKER, JR. 

District Attorney, in and for 

Hunt County, Texas 

STEVE Ll LLEY 

Assistant District Attorney 

State Bar Number- 24046293 

P.O. Box 441 

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

CLERK

 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 9/11/2015 3:25:31 PM DEBBIE AUTREY Clerk
STATE'S SECOND MOTION FOR EXTENSION OF TIME TO FILE 

STATE'S BRIEF 

Comes now, The State of Texas, and files this, her First Motion for 

Extension of Time to File State's Brief. 

I. 

The current filing deadline for the State's brief is September 11, 

2015. 

II. 

The State's brief was originally due in this case on August 24, 2015. 

On August 26, 2015, a member of the District Attorney's Office filed a first 

request for extension of time to file a brief in this case. The extension was 

requested for a period of eighteen (18) days from the original due date. 

The Court granted the extension and the brief was then due on September 

11, 2015. However, the attorney responsible for drafting the brief in this 

case (as he tried the case in front of a jury and handled the suppression 

hearing) was, during this time, in the midst of a murder trial entitled The 

State of Texas v. Joshua Madison Newkirk, Cause No. 29,984. This trial 

began on August 24, 2015 and was not finished until the late evening of 

September 1, 2015. Early the next morning, the same prosecutor left for 

on a prearranged trip to the State of New Mexico to research background 

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information on a capital murder case entitled The State of Texas 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, September 4, 2015 to work on 

a number of matters, including this appeal, that had been accumulating for 

the past several weeks. As the Court is aware, Monday, September 7 was 

a holiday. With only three working days remaining before the brief was 

due, the prosecutor has regrettably been unable to complete work on the 

brief. 

Ill. 

The State therefore requests an additional three weeks time to 

complete its work on the brief. Specifically, the State requests a due date 

of October 2, 2015. 

IV. 

The State has made one previous requests for extensions to file her 

brief in this case. 

V. 

For the reasons stated hereinabove, it is respectfully requested that 

this Court grant the State of Texas until October 2, 2015, to file her brief. 

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_/Steve Lilley 

Assistant District Attorney 

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 certify that I have conferred with Appellant's attorney and he does 

not object to the requested extension of time. 

~eLilley ~;t~ 

CERTIFICATE OF SERVICE 

This is to certify that a true copy of this Motion to Extend Time to File 

State's Brief has been forwarded to Mr. Jason Duff by placing a copy in his 

mailbox in the district clerk's office per lo 

Steve Lilley 

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