### No. 12-15-00032-CR IN THE COLIRT OF APPEALS OF THE STATE OF TEXAS TWELFTH SUPREME JUDICIAL DISTRICT TYLER,TEXAS

MITZI GAILALLGOR, ApPELLANT 

## v. THE STATE OFTEXAS
TRIALCOURTCAUSE No. CF1302374 COUNTYCOURTAT 

### LAw, NACOGDOCHESCOUNTY,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 ofTime 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 toJuly 24,2015. For cause, The State would show untothe Court as follows: I. 

### The State seeks an extension oftime forthe 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 CLERKoffice is burdened with an ever-increasing caseload, which requires the full-time attention ofall 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 preparingthe brief. III. This is the first extension requested. The State respectfully requests that it be given an extension untilJuly 24, 2015, tofile 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 whichtofileThe State's Brief. Respectfully submitted,

Stephanie Ste hens Assistant County Attorney 101W. 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 Stephenswho after being dulysworn upon his oath did depose and state: liMy name is Stephanie Stephens and I am the attorney of record forthethe State ofTexas in the foregoing entitled and numbered cause. 'am familiar with thefacts and allegations contained in the foregoing Motion for Extension of Time for Filing the State's Brief, and theyare true and correcttothe best of my knowledge. II

Stephanie Stephens

SUBSCRIBED AND SWORN to before methisthe 

### 24th day ofJune, 

### 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 atrue and correct copy ofthe 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.

# SteP**hanie~**