No. 12-15-00032-CR 


IN THE COLIRT OF APPEALS OF THE STATE OF TEXAS 


TWELFTH SUPREME JUDICIAL DISTRICT 


TYLER,TEXAS 


MITZI GAIL ALLGOR, 


ApPELLANT 


v. 

THE STATE OF TEXAS 

TRIAL COURT CAUSE No. CF1302374 


COUNTY COURT AT LAw, NACOGDOCHES COUNTY, TEXAS 


MOTION FOR EXTENSION OF TIME FOR FILING 


STATE'S BRIEF 


TO THE HONORABLE JUSTICES OF SAID COURT: 

COMES NOW, THE STATE OF TEXAS, by and through the undersigned Nacogdoches 

County Assistant County Attorney, and respectfully request that this Honorable Court 

grant an Extension of Time for Filing the State's Brief. The present date for filing the Brief 

is Friday, June 19, 2015, and it is respectfully requested that said time be extended to July 

24,2015. 

For cause, The State would show unto the Court as follows: 

I. 


The State seeks an extension of time for the following reasons: 


1. The Nacogdoches County Attorney's Office is staffed by four attorneys. Presently, the 

ACCEPTED

12-15-00032-CR

TWELFTH COURT OF APPEALS

TYLER, TEXAS

6/24/2015 2:05:21 PM

CATHY LUSK

CLERK

 FILED IN 12th COURT OF APPEALS TYLER, TEXAS 6/24/2015 2:05:21 PM CATHY S. LUSK Clerk
office is burdened with an ever-increasing caseload, which requires the full-time 

attention of all four attorneys. 

2. 	 The undersigned Assistant County Attorney has been involved in preparing for 

numerous trials, trial settings, other Court hearings, and appellate work in both 

criminal cases and cases involving Children's Protective Services, which prevented 

counsel from reading the Statement of Facts, reviewing the law as pertaining to those 

facts and preparing the brief. 

III. 

This is the first extension requested. The State respectfully requests that it be given an 

extension until July 24, 2015, to file its brief. 

IV. 

This motion is urged at the first opportunity, as The State will suffer irreparable harm if 

it is not granted. 

WHEREFORE, PREMISES CONSIDERED, The State prays that this Honorable Court grant 

this Extension ofTime in which to file The State's Brief. 

Respectfully submitted, 

Stephanie Ste hens 

Assistant County Attorney 

101 W. Main, No. 230 

Nacogdoches, Texas 75961 

936.560.7788 

Fax 936.560.7809 

Bar #19160055 
1 

THE STATE OF TEXAS § 

COUNTY OF NACOGDOCHES § 

BEFORE ME, the undersigned authority, on this day personally appeared Stephanie 

Stephens who after being duly sworn upon his oath did depose and state: 

liMy name is Stephanie Stephens and I am the attorney of record for the the State of Texas 

in the foregoing entitled and numbered cause. 'am familiar with the facts and allegations 

contained in the foregoing Motion for Extension of Time for Filing the State's Brief, and 

they are true and correct to the best of my knowledge.II 

Stephanie Stephens 

SUBSCRIBED AND SWORN to before me this the 24th day of June, 2015. 

~~~~~~-.---~ BILLIE TILL/;:: 

Notary Public, Stela of T~;:C3 

r.:y Commission h""ro~ 

April ~ai\'; 

CERTIFICATE OF SERVICE 

I, Stephanie Stephens, hereby certify that a true and correct copy of the Motion for 

Extension of Time for Filing the State's Brief has been served upon the Appellant by 

sending the same through U.S. Mail to her attorney, Noel Cooper, Appellate Counsel for 

Appellant, 117 North Street, Suite, 2, Nacogdoches, Texas 75961. 

DATE: June 24, 2015. 

StePhanie~