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: .
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• 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.
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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
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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
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