NO. 06

- 15 -00216- CR 06

- 15 -00221- CR RICHARD TURNER , § ON APPEAL FROM THE Appellant § § 102 nd 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 pursuant to Texas Rules of Appellate Procedure and hereby requests a thirty (30 ) day extension of the time period for the filing of the State’s Brief and in support of the same should show the Court as follows: I. 1. This case is pending from the 102 ND Judicial District of Bowie County, Texas. 2. The case is styled State of Texas v. Richard Turner , Cause Numbers 13F0312- 102, 13F0329-102. 3. Appellant’s Brief

was filed on April 18, 2016 making the State’s Brief orig in ally due on or about May 18, 2016
. ACCEPTED 06-15-00220-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 6/17/2016 4:23:04 PM DEBBIE AUTREY

CLERK6. The State has previously requested an extension of time for filing the State’s Brie f , making State ’ s Brief due June 17, 2016
. 7. 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 and attendance at th e pre - indictment and regular dockets of the 5 th District Court on April 18, 2016.

 Pre

- trial meetings on April 12

- 13, 2016 in State of Texas v. Dominique Robertson, Deadly Conduct, Cause No. 14F0290

- 102 and 14F0681

- 102, set for trial April 22, 2016.

 Prepar ation of the appellate brief in Delbert Sisemore v. State of Texas, 06

- 15

- 00143

- CR, which is due April 27, 2016 and in which the State has already requested an extension of time to file brief.

 Preparation of the appellate brief in Delbert Sisemore v. Stat e of Texas, 06

- 15

- 00143

- CR, which is due April 27, 2016 and in which the State has already requested an extension of time to file brief.

 Pre

- trial meetings, preparation and attendance at the trial of State of Texas v. Annette Harris, Theft <$1500 with two prior theft convictions, April 26

- 27, 2016. Pre

- trial meetings, preparation and attendance at the trial of State of Texas v.

Brodrick Walker, Aggravated Sexual Assault of a Child, Cause No. May 10

- 12, 2016.

 Preparation and attendance at the pre

- indictmen t and regular dockets of the 5 th District Court on May 16, 2016.

 Preparation and attendance at the Grand Jury proceedings on May 19, 2016

 Preparation and trial in the case, State of Texas v. Candy H a gler 15F0436

- 005, DWI 3 rd or More, May 23

- 26, 2016.

 Preparation and atten dance at the Grand Jury proceedings on June 2, 2016
.
 Preparation of State ’ s Brief in James Friend v. State of Texas, 06

- 15

- 0009

- CR, which was filed June 6, 2016.

 Preparation and trial in the case, State of Texas v. Miranda Steitler, Cause Nos. 15F0779

- 005 and 15F0780

- 005, set for trial June 14, 2016.

 Preparation and attendance at the regular and pre

- indictment doc kets in the 5 th District Court on June 13, 2016.

 Preparation of State ’ s Brief in Lorenzo Ma r tinez v. State of Texas, 06

- 15

- 00216

- CR. II. The State’s attorney has been diligent in pursuing this appeal and is not seeking this exte nsion for the purpose of delay.PRAYER

WHEREFORE, on the bases of Rule 73 of the Texas Rules of Appellate Procedure, the State respectfully requests this Court to grant the Motion for Extension of Time for the filing of the State’s Brief. Respectfully submitted,

Respectfully submitted, __/s/ Lauren N. Sutton______ LAUREN N. SUTTON Texas Bar No. 24079421 601 Main Street Texarkana, TX 75501 Lauren.sutton@txkusa.org ASSISTANT DISTRICT ATTORNEY

CERTIFICATE OF SERVICEI 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. Craig Henry , coun sel for Appellant, on this the 17th day of June , 2016
. __/s/ Lauren N. Sutton__

_ ___ LAUREN N. SUTTON