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No. 14-15-00154-CR

ANTHONY PLASTER § IN THE COURT OF APPEALS

§

V. § 14TH JUDICIAL DISTRICT

§

THE STATE OF TEXAS § AT HOUSTON, TEXAS

APPELLEE’S MOTION TO EXTEND TIME TO FILE THE BRIEF

TO THE HONORABLE COURT OF APPEALS: 

Appellee asks the Court to extend the time to file its brief. 

Introduction 

1. Appellant is Anthony Plaster; Appellee is the State of 

Texas. No rule provides a deadline to file this motion to extend. See TEX.

R. APP. P. 38.6(d). The Appellant is unopposed to this motion. 

Argument and Authorities 

 2. The Court has the authority under Texas Rule of 

Appellate Procedure 38.6(d) to extend the time to file the brief. Appellant’s 

brief was filed on November 9, 2015. Appellee’s brief is due on December 

9, 2015. Appellee requests 30 days to file its brief, extending the time until 

January 8, 2016. No prior extension has been granted to extend the time to 

file the Appellee’s brief. 

ACCEPTED

14-15-00154-CR

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

12/8/2015 10:41:27 AM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 12/8/2015 10:41:27 AM CHRISTOPHER A. PRINE Clerk
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3. Appellee request additional time to file its brief because 

the undersigned counsel has been finishing two other complicated briefs, 

with extensive records, that have deadlines close in time to the instant case. 

Counsel has made a diligent effort to complete all briefs within the time 

designated by the rules. Counsel has been faced with a large end-of-the-year 

conclusion volume in his other cases as well. As a result, counsel will not be 

able to complete the brief by the current due date.

Prayer

4. For these reasons, Appellee asks the Court to grant an 

extension of time to file its brief until January 8, 2016.

Respectfully submitted,

/s/ Trey D. Picard

_____________________________________

Trey D. Picard

State Bar No. 24027742

Assistant Criminal District Attorney

111 East Locust St., Suite 408A

Angleton, Texas 77515

(979) 864-1233 

(979) 864-1712 Fax

treyp@brazoria-county.com

ATTORNEY FOR THE APPELLEE,

THE STATE OF TEXAS
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CERTIFICATE OF CONFERENCE

As required by Texas Rule of Appellate Procedure 10.1(a)(5), I 

certify that I have conferred, or made a reasonable attempt to confer, with all 

other parties, which are listed below, about the merits of this motion with the 

following results:

Faye Gordon

Attorney at Law

201 E. Myrtle St.

Angleton, Texas 77515

(979) 849-3330

faye@fayegordonlaw.net

Attorney for the Appellant

 opposes motion

 does not oppose motion

 agrees with motion

 would not say whether 

motion is opposed

 did not return my message 

regarding the motion

/s/ Trey D. Picard

______________________________

Trey D. Picard

Assistant Criminal District Attorney
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CERTIFICATE OF SERVICE

As required by Texas Rule of Appellate Procedure 6.3 and 

9.5(b), (d), (e), I certify that I have served this document on all other parties, 

which are listed below, on December 8, 2015:

Faye Gordon

Attorney at Law

201 E. Myrtle St.

Angleton, Texas 77515

(979) 849-3330

faye@fayegordonlaw.net

Attorney for the Appellant

By:

 personal delivery

 mail

 commercial delivery 

 electronic delivery / fax

/s/ Trey D. Picard

______________________________

Trey D. Picard

Assistant Criminal District Attorney