NO. 06-15-00011-CR

TERRANCE LAVON DAVIS, § ON APPEAL FROM THE 

 Appellant § 

 § 202ND JUDICIAL DISTRICT 

VS. § 

 § 

STATE OF TEXAS, § COURT OF BOWIE COUNY 

 Appellee § TEXAS 

 

SECOND MOTION TO EXTEND TIME FOR FILING STATE’S BRIEF

TO THE HONORABLE JUDGE OF SAID COURT: 

COMES NOW the State of Texas by and through her below named Criminal 

District Attorney and for its Motion for Belated Filing of Appellee’s Brief states as 

follows: 

I.

1. This case is pending from the 202nd Judicial District of Bowie County, Texas. 

2. The case is styled State of Texas v. Terrence Lavon Davis, Cause No. 14F0109-

202. 

3. Appellant was found guilty of two counts of Aggravated Robbery and sentenced 

to fifty-five (55) years in the Texas Department of Criminal Justice. 

4. Appellant’s Brief was filed on July 9, 2015, making the State’s Brief originally 

due on or about August 10, 2015. 

ACCEPTED

06-15-00011-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

9/9/2015 7:59:46 PM

DEBBIE AUTREY

CLERK

 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 9/9/2015 7:59:46 PM DEBBIE AUTREY Clerk
5. The State has previously requested an extension of time for filing a brief, making

the State’s brief due on September 9, 2015.

II.

The Brief was not timely prepared in this matter due to the press of the business, 

both trial and appellate. Said business includes, but is not limited to, the following 

since Appellant’s brief was filed:

 Preparation of the State’s brief in Kevin Fahrni v. State of Texas, 06-14-

00148-CR, which was due on June 17, 2015.

 Preparation for the pre-trial docket in the 5th District Court on June 15, 2015.

 In addition to the aforementioned work matters, the attorney for the State 

handling this appeal was out of the country on vacation from June 4-13, 2015.

 Preparation of the State’s brief in Reginald Reece v. State of Texas, 6-14-

00192-CR, which was filed on June 22, 2015.

 Pre-trial meetings and preparation for the trial of State of Texas v. Delbert 

Sisemore, Aggravated Robbery, Burglary of Habitation, Possession of a 

Controlled Substance, during the week of June 22, 2015. Trial was held on 

June 30-July 1, 2015.

 Preparation and attendance at the pre-trial and trial dockets in the 5th District 

Court on June 29, 2015.
 Pre-trial meetings and preparation for the trial of State of Texas v. Delbert 

Sisemore, Aggravated Robbery, Burglary of Habitation, Possession of a 

Controlled Substance, during the week of June 22, 2015. 

 Trial of State of Texas v. Delbert Sisemore was held on June 30-July 1, 2015.

 Pre-trial meetings and preparation for the trial of State of Texas v. Gary 

Carson, 14F0102-102, 14F0103-102, and 14F0161-102, Assault on a Public 

Servant (x3) on July 7-9, 2015.

 Preparation and attendance at the Trial dockets in the 5th District Court on July 

13, 2015.

 Trial of State of Texas v. Gary Carson 14F0102-102, 14F0103-102, and 

14F0161-102, Assault on a Public Servant (x3) was set for jury selection on 

July 14, 2015. 

 Preparation of the State’s Brief in Roderick Beham v. State of Texas, Cause 

No. 06-14-00174, which was filed on July 22, 2015.

 Attendance at the Advanced Criminal Law Continuing Legal Education 

Conference in San Antonio, Texas on July 26-31, 2015.

 Pre-trial meetings and preparation for trial in State of Texas v. Steven 

Lorance, 15F0323-005 on August 4, 2015. The case was resolved short of a 

trial at a hearing on August 7, 2015.

 Preparation and attendance at the Grand Jury proceedings on August 20, 2015.
 Preparation and attendance at the Trial docket in the 5th District Court on 

August 24, 2015.

 Attendance at the Capital and Non-Capital Training for the Prosecution CLE 

in Plano, Texas, August 26-28, 2015.

 Preparation of the Appellate brief in Richard Darby v. State of Texas, Cause 

No. 06-15-0042-CR, 06-15-0043-CR, 06-15-0044-CR, 06-15-0045-CR, 06-

15-0046-CR, which was filed on August 31, 2015.

 Preparation of the Appellate brief in Donald Brown v. State of Texas, Cause 

No. 06-14-00183-CR, which was filed on September 9, 2015.

III.

The State’s attorney has been diligent in pursuing this appeal. This motion is 

made in good faith and not for purposes of delay.
PRAYER

WHEREFORE, on the bases of Rule 73 rule of the Texas Rules of Appellate 

Procedure, the State respectfully requests this court to grand the Motion for 

Extension of Time for the filing of the State’s Brief. 

Respectfully submitted,

__/s/ Lauren N. Sutton______

LAUREN N. SUTTON

Texas Bar No. 24079421

601 Main Street

Texarkana, TX 75501

ASSISTANT DISTRICT 

ATTORNEY

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and foregoing Motion to 

Extend Time for Filing State’s Brief was forwarded to Mr. Al Smith counsel for 

Appellant, on this the 9th day of September, 2015. 
__/s/ Lauren N. Sutton______ 

LAUREN N. SUTTON