WR-48,152-08
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 6/1/2016 12:21:15 PM
June 1, 2016 Accepted 6/1/2016 12:33:29 PM
ABEL ACOSTA
No. WR-48,152-08 CLERK
♦
In the
Court of Criminal Appeals
At Austin
♦
Ex Parte
GARCIA GLEN WHITE
Applicant
♦
On Application for Writ of Habeas Corpus
From the 180th District Court of Harris County, Texas
No. 723847
♦
APPLICANT’S MOTION FOR EXTENSION IN TIME IN WHICH
TO CORRECT DEFICIENCIES IN MAY 24, 2016 RESPONSE
♦
TO THE HONORABLE JUSTICES OF THE
COURT OF CRIMINAL APPEALS OF TEXAS:
COMES NOW, the Applicant, Garcia Glen White, by and through his attorneys
of record, Patrick F. McCann and Mandy Miller, and respectfully moves this
Honorable Court to extend the time for filing his Response to this Court’s Order of
March 23, 2016, up to and including June 1, 2016. In support of such motion, the
Applicant would show the Court the following:
(1) After receiving one extension in time up to and including May 24,
2016, in which to file a Response worthy of this Court’s attention, the Applicant
timely filed his Response on May 24, 2016.
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(2) The undersigned counsel were advised telephonically by the Clerk of
this Court on June 1, 2016, that the Applicant’s Response was deficient and had
been rejected for filing because of the unintended omission of the Certificate of
Compliance with respect to the word count of the Response.
(3) The undersigned have corrected this deficiency and,
contemporaneously with the filing of this motion for extension in time, have re-
submitted the corrected Response.
(4) The undersigned apologize to both the Court and its Clerk for any
inconvenience this omission may have caused, and make assurances that steps
have been taken to ensure that this does not happen again.
PRAYER
WHEREFORE, PREMISES CONSIDERED, the Applicant prays that this Honorable
Court will, in all things, GRANT this motion, and permit the filing of the
Applicant’s corrected Response to this Court’s March 23, 2016 Order, and that the
Court further GRANT any additional relief to which the Applicant may be legally
and justly entitled.
DATED this 1ST day of June, 2016.
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Respectfully submitted,
PATRICK MCCANN
State Bar No: 00792680
writlawyer@justice.com
MANDY MILLER
State Bar No: 24055561
mandy@mandymillerlegal.com
909 Texas Ave., Ste. 205
Houston, TX 77002
(713) 223-3805
Fax (713) 226-8097
Attorneys for the Applicant
GARCIA GLEN WHITE
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CERTIFICATE OF SERVICE
Applicant has sent a copy of the foregoing instrument to counsel for the
State of Texas at the following electronic mail addresses on this 1st day of June,
2016:
Lynn Hardaway
Harris County Assistant District Attorney
hardaway_lynn@dao.hctx.net
Lori DeAngelo
Harris County Assistant District Attorney
deangelo_lori@dao.hctx.net
PATRICK MCCANN
MANDY MILLER
Attorneys for the Applicant
GARCIA GLEN WHITE
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