Elena Antoinette Bradford v. State

ACCEPTED 14-15-00707-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 7/8/2016 9:25:21 AM CHRISTOPHER PRINE CLERK NO. 14-15-00707-CR FILED IN ELENA ANTOINETTE IN THE COURT OF APPEALS 14th COURT OF APPEALS BRADFORD, HOUSTON, TEXAS APPELLANT 7/8/2016 9:25:21 AM CHRISTOPHER A. PRINE FOURTEENTH SUPREME Clerk v. JUDICIAL DISTRICT THE STATE OF TEXAS, HOUSTON, TEXAS APPELLEE MOTION FOR EXTENSION OF TIME TO FILE STATE'S RESPONSE BRIEF TO THE HONORABLE COURT OF APPEALS: Now comes Jack Roady, Criminal District Attorney of Galveston County, Texas, pw:suant to Rule 10.5(b), Texas Rules of Appellate Procedw:e, and moves for an extension of time in which to file the State's Brief and would respectfully show the Court of Appeals as follows: 1. The appellant was convicted of FAILURE TO REPORT CHILD ABUSE, and was sentenced on 8/18/2015. The trial case was styled as State of Texas v. Elena Antoinette Bradford, in County Court at Law #1 of Galveston County, Texas, Cause No. MD-348870. Appellant filed timely Notice of Appeal. The Appellant's brief was filed with this Court on 4/13/2016. 2. The present due date for filing the State's brief is 7/13/2016. 3. This is the State's second motion for extension of time to file its brief. 4. The State requests an extension to file its brief on or before 7/27/2016. 5. The State requests this extension not for delay but because dw:ing the last thirty days, the undersigned attorney for the State: . 1 • Completed a reply brief on Luis Eduardo Lara v. State, 14-15-00581-CR 14-15-00582-CR 14-15-00583-CR filed on 6/1/2016 • Supervised a reply brief on Bretton Fox v. State, 01--15-00986-CR filed on 6/13/2016. • Supervised a reply brief on Marcos Jimenez v. State, 01-15-00501-CR & 01-15-00506-CR filed on 6/15/2016. • Supervised a reply brief on John Davis. Campbell v. State,01-16-00131-CR filed on 6/16/2016. • Completed a reply brief on Michael Enriquez v. State, 01-15-00893-CR filed on 6/17/2016. • Completed a reply brief on Darryl Evans v. State, 01-15-00455-CR filed on 6/27/2016. • Supervised a reply brief on Marshall Darnell Joshua v. State, 01-15-01060- CR, filed on 7/7/2016. • Is solely responsible for all Post-Conviction Writs of Habeas Corpus for Galveston County and completed 4 post-conviction writ answers on case numbers: 07-CR-3271-83-1 (jesse Berry); 15-CR-1097-83-1 (james Hannington); 12-CR-0628-83-1 (Troy Marce~; 12-CR-2884-83-1 (juan Munera-Ortega). • The undersigned attorney also was responsible for gathering the initial discovery for Marcus Shuff (10-CR-0506) & Robert Villanueva (08-CR-3051). Both cases are in the early stages of possible post-conviction DNA litigation. WHEREFORE, PREMISES CONSIDERED, the State respectfully requests that this Court of Appeals extend the time to file the State's brief until July 27,2016. 2 Respectfully submitted, JACK ROADY CRIMINAL DISTRICT ATTORNEY GALVESTON COUNTY, TEXAS IsI Rebecca Klaren REBECCA KLAREN Assistant Criminal District Attorney 600 59 th Street, Suite 1001 Galveston County, Texas 77551 Tel.(409)766-2355, fax (409)766-2290 State Bar Number: 24046225 rebecca.klaren@co.galveston. tx. us CERTIFICATE OF COMPLIANCE The undersigned Attorney for the State certifies this brief is computer generated, and consists of 354 words. lsI Rebecca Klaren REBECCA KLAREN Assistant Criminal District Attorney Galveston County, Texas CERTIFICATE OF SERVICE The undersigned attorney for the State certifies that a copy of the above motion was emailed via eFiling e-service to Greg Russell, attorney for Appellant, greg@gnrlaw.com on July 8, 2016. lsI Rebecca Klaren REBECCA KLAREN Assistant Criminal District Attorney Galveston County, Texas 3 AFFIDAVIT THE STATE OF TEXAS COUNTY OF GALVESTON Before me, the undersigned authority, on July 8, 2016, appeared Rebecca Klaren, who by me duly sworn did depose and state on oath the following: "I, Rebecca Klaren, Attorney for the State of Texas, have read the Motion for Extension of Time to File the State's Brief, and swear that the information contained therein is true and correct." ~~ REBECCA KLAREN Assistant Criminal District Attorney Galveston County, Texas SWORN TO AND SUBSCRIBED before me onJuly 8, 2016. ".-:.~~II~~IIII HEATHER GRUBEN !~:-:.:J:)1''§. Notary Public. State of Texas ~"';:.l"f..:~j My Commission Expires "'::'i,:f,\:!~~·l May 06.2019 NOTARY PUBLIC in and for the State of Texas 4