                                                                                                         ACCEPTED
                                                                                                    06-14-00105-CR
                                                                                          SIXTH COURT OF APPEALS
                                                                                               TEXARKANA, TEXAS
                                                                                                3/6/2015 2:19:11 PM
                                                                                                    DEBBIE AUTREY
                                                                                                             CLERK

                              NO. 06-14-00105-CR
  __________________________________________________________________________
                                                                                 FILED IN
                                IN THE COURT OF APPEALS                   6th COURT OF APPEALS
                                                                            TEXARKANA, TEXAS
                                           FOR THE                        3/6/2015 2:19:11 PM
                                SIXTH APPELLATE DISTRICT                      DEBBIE AUTREY
                                                                                  Clerk
                                  AT TEXARKANA, TEXAS
 ___________________________________________________________________________
                                Timothy Paul Bates, APELLANT
                                               V.
                             THE STATE OF TEXAS, APPELLEE
 ___________________________________________________________________________
                          APPEAL IN CAUSE NUMBER CR1301437
                            IN THE COUNTY COURT AT LAW #2
                                 OF HUNT COUNTY, TEXAS
                          JUDGE DUNCAN THOMAS PRESIDIING
  __________________________________________________________________________


                           APPELLEE MOTION FOR EXTENSION


TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:


        NOW COMES, Joseph T. O’Neill, Appellee and Attorney for the State, makes and files
this Motion for Extension and would respectfully show the following:
                                                I.

       Appellee’s Brief is due March 5, 2015. The request for extension is made for the

following reason: Appellee maintains a regular docket in County Court at Law #2 in Hunt

County, as well as multiple Justice of the Peace courts. Trials in cause numbers

CR1400590/CR1400591, CR1401274, and CR1400453 have caused Appellee to not have the

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Motion for Continuance                                         Page 1 of 2
time to prepare a proper breif for the court's consideration. A string of bad weather on 2/23/15,

2/24/15 and 3/5/15 have caused Appellee to not be in the office to give additional time to work

on this appeal.



                                                  II.

       Appellee moves for a 30 day extension in this matter. This Motion for Extension is in the

interest of justice and not for the purpose of delay.


       WHEREFORE PREMISES CONSIDERED, Appellee prays the Court grant this, its
Motion for Extension, in the above numbered cause.




                                                        Respectfully submitted,

                                                        ____/S/___Joseph T. O’Neill_________
                                                        Joseph T. O’Neill
                                                        Assistant Hunt County Attorney
                                                        State Bar No. 24076953



                                     CERTIFICATE OF SERVICE

           A true and correct copy of the foregoing Motion for Extension was served on counsel
for Appellant.


                                                        ___/S/___Joseph T O’Neill________
                                                        Joseph T. O’Neill




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Motion for Continuance                                         Page 2 of 2
