Case Information

*0 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 5/22/2015 2:38:22 PM DEBBIE AUTREY Clerk *1 ACCEPTED 06-14-00192-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 5/22/2015 2:38:22 PM DEBBIE AUTREY CLERK NO. 06-14-00192-CR

REGINALD REECE, § ON APPEAL FROM THE

Appellant § 202 ND JUDICIAL DISTRICT

§ VS. §

STATE OF TEXAS, § COURT OF BOWIE COUNY

Appellee § TEXAS

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:

1. This case is pending from the 202 Judicial District of Bowie County, Texas.

2. The case is styled State of Texas v. Reginald Reece , Cause No. 11F0746-202.

3. Appellant was found guilty to the offense of Theft with Priors and sentenced to

twenty (20) years in the Institutional Division of the Texas Department of Criminal

Justice and $10,000.00 fine.

5. Appellant’s Brief was filed on April 21, 2015 making the State’s Brief originally

due on or about May 21, 2015.

6. The State not previously requested an extension of time for filing a brief.

7. 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 for the trial and pre-indictment dockets for the 202 nd District

Court scheduled for April 27, 2015

 Preparation and attendance at the trial and pre-indictment dockets for the 5 th

District Court on May 4, 2015.

 Preparation and attendance at the trial and pre-indictment dockets for the

202 District Court on May 11, 2015.

 Preparation and attendance at the trial and pre-indictment dockets for the 5 th

District Court on May 18, 2015

 Pre-trial conferences and trial preparation for Jury Trial from May 19-21,

2015 in State of Texas v. Antonio Moore, Murder- 14F0611-102, Intoxication

Assault- 14F0612-102.

 Pre-trial conferences and trial preparation on Matthew Schneider, DWI 3 rd or

more- 14F0324-202, DWI 3 rd or More- 14F0724-202, DWI 3 rd or more-

14F0778-202, which was set for trial on May 26, 2015. The case was resolved

by plea agreement at the final pretrial on May 21, 2015.

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, __/s/ Lauren N. Sutton______ LAUREN N. SUTTON Texas Bar No. 24079421 601 Main Street

Texarkana, TX 75501 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. Alwin Smith, counsel

for Appellant, on this the 22nd day of May, 2015.

__/s/ Lauren N. Sutton______ LAUREN N. SUTTON