NO. 06-15-00216-CR

06-15-00221-CR

RICHARD TURNER , § ON APPEAL FROM THE 

 Appellant § 

 § 102nd 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 102ND 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 originally 

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

CLERK

 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 6/17/2016 4:23:04 PM DEBBIE AUTREY Clerk
6. The State has previously requested an extension of time for filing the State’s Brief, 

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 the pre-indictment and regular dockets of the 5th

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.

 Preparation 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. 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.

 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-indictment and regular dockets of the 5th

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 Hagler 15F0436-

005, DWI 3rd or More, May 23-26, 2016.

 Preparation and attendance 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 dockets in the 5th

District Court on June 13, 2016.

 Preparation of State’s Brief in Lorenzo Martinez 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 

extension 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 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. Craig Henry, counsel 

for Appellant, on this the 17th day of June, 2016. 

__/s/ Lauren N. Sutton______ 

LAUREN N. SUTTON