ACCEPTED
14-14-00961-cr
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
2/9/2015 11:08:05 AM
CHRISTOPHER PRINE
CLERK
NO. 14-14-00960-CR & 14-14-00961-CR
CALLIE RENEE INMAN, IN THE COURT OF APPEALS
APPELLANT FILED IN
14th COURT OF APPEALS
HOUSTON, TEXAS
v. FOURTEENTH 2/9/2015 11:08:05
SUPREME
AM
JUDICIAL DISTRICT
CHRISTOPHER A. PRINE
Clerk
THE STATE OF TEXAS,
APPELLEE HOUSTON, TEXAS
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,
pursuant to Rule 10.5(b), Texas Rules of Appellate Procedure, 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 charged with of intoxicated manslaughter with vehicle and
intoxicated assault with vehicle causing serious bodily injury. The case is styled as
State oj Texas v. Co/lie Rmee II/mOIl, in the 56'111 Judicial District Court of Galveston
County, Texas, Cause No. 14-CR-0611 & 14-CR-0612. An Application for Writ of
Habeas Corpus was filed 11/14/2014 and denied 11/25/2014. Appellant filed
timely Notice of Appeal. The Appellant's brief was filed with this Court on
January 20, 2015.
2. The present due date for filing the State's brief is February 9, 2015.
3. This is the State's first motion for extension of time to file its brief.
4. The State requests an extension to file its brief on or before April 9, 2015.
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5. The State requests this extension not for delay but because during the last seventy-
five days, the undersigned attorney for the State:
• Has been working on a rather large and complex State's appeal on
State v. Hector Pma, 14-14-00746-CR It is due on 2/11/2015.
• Has been working on a supplemental brief ordered in Javia Sillqlfize JOhllSOl1 v.
State, 01-14-00185-CR, due on 2/12/15.
• Assisted in preparing for Oral Arguments on Villcmt Zahorik v. State, 14-13-
00763-CR Oral Arguments were set for 11/17/14 and reset the same day.
Arguments were held on 1/12/2015.
• Completed the State's response brief on Vallessa Vall-Ness v. State, 01-13-
00607-CR on January 7, 2015.
• Completed the State's response brief on Adams OIfZeJ/1IC v. State, 01-14-00242-
CR on December 16, 2014.
• Completed the State's response brief on Howard Hams v. State, 14-14-000391-
CR & 14-14-000392-CR on December 3, 2014.
• Is solely responsible for all Post-Conviction Writs of Habeas Corpus for
Galveston County and completed 6 post-conviction writ answers on case
numbers: 13-CR-2144-83-1 (Earl Morrhead); 11-CR-3078-83-1 (RolUfy OWCIIS);
11-CR-021O-83-2 (JB Degrassa); 37968-83-2 (Michael Richie); 08-CR-2835-83-1
(Pedro Cabrrra) 11-CR-1177-83-1, 11-CR-1178-83-1, 11-CR-1179-83-1 (Michael
Shqyne Hallsley) 03-CR-0733-83-4 (RJ/Ssel/ Kevill Thompsoll).
• Was out of state for nearly 2 weeks.
• During the Christmas and New Year's Holidays, caught the flu and was out
sick for several days.
6. The State must also complete its response brief to Bralldoll Derrail EvallS v.
State, 01-14-00345-CR, due on 3/9/2015.
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7. The State must also complete its response brief to Fahd Saad Tallash v. Siale,
14-14-00463-CR, due on 3/16/2015.
8. The State must also complete its response brief to Del/llis Roy Reddillg v. Siale,
01-14-00536-CR, due on 2/9/2015.
9. The State must also complete its response brief to Liollel Frallklill v. Siale, 14-
14-00559-CR, due on 2/17 /2015.
10. The State must also complete its response brief to ClYde Edwill Hedrick v. Siale,
14-14-00378-CR, due on 4/6/2015.
11. The State must also complete its response brief to Joshlla Dwtrylle Bledsoe v.
Slate, 14-14-00380-CR, due on 3/9/2015.
WHEREFORE, PREMISES CONSIDERED, the State respectfully requests
that this Court of Appeals extend the time to file the State's brief until ApriJ9, 2015.
Respectfully submitted,
JACK ROADY
CRIMINAL DISTRICT ATTORNEY
GALVESTON COUNTY, TEXAS
lsI Rebecca Klarel/
REBECCA KLAREN
Assistant Criminal District Attorney
600 59 th Stteet, Suite 1001
Galveston County, Texas 77551
Tel.(409)766-2355, fax (409)766-2290
State Bar Number: 24046225
rebecca.klaren@co.galveston.tx.us
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CERTIFICATE OF COMPLIANCE
The undersigned Attorney for the State certifies this brief is computer generated,
and consists of SIS words.
lsI Rebecca Klarev
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 faxed! emailed! eFiled ! or mailed to Jeth Jones, Attorney for Appellant, at
jjones@joneslawfirm.com or 1100 Rosenburg Ave, Galveston, TX 77550, on
February 9, 2015.
lsI Rebecca Klare/l
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 February 9, 2015, 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."
~~~~
Assistant Criminal District Attorney
Galveston County, Texas
SWORN TO AND SUBSCRIBED before me on February 9, 2015.
~ n.1~
NOTARY PUBLIC in and for
the State of Texas
e! t
•• •
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CAlHeRINEN. NELSON
MY COMMISSION EXPIRES
FebnlaIy 19. 2017