ACCEPTED
14-14-00380-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
3/9/2015 9:27:43 AM
CHRISTOPHER PRINE
CLERK
NO. 14-14-00380-CR
JOSHUA DWAYNE BLEDSOE, IN THE COURT OF APPEALS
FILED IN
APPELLANT 14th COURT OF APPEALS
HOUSTON, TEXAS
3/9/2015 9:27:43 AM
v. FOURTEENTH CHRISTOPHER SUPREME
A. PRINE
JUDICIAL DISTRICT 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 convicted of unauthorized use of a motor vehicle, and was
sentenced on 4/4/2014. The trial case was styled as State of Texas v. Joshlla Dwcryne
Bledsoe, in the 405th Judicial District Court of Galveston County, Texas, Cause No.
09CR0075. Appellant filed timely Notice of Appeal. The Appellant's brief was
filed with this Court on 2/6/2015.
2. The present due date for filing the State's brief is 3/9/2015.
3. This is the St.'lte's first motion for extension of time to file its brief.
4. The State requests an extension to file its brief on or before 5/9/2015.
5. The State requests this extension not for delay but because during the last sixty
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days, the undersigned attorney for the State:
• Completed the State's response brief on Fahd Tallash v. State, 14-14-00463-CR
on March 6, 2015.
• Completed the State's response brief on Bralldoll EVOIIS v. State, 01-13-00345-
CR on February 23, 2015.
• Completed the State's response brief on Elijah Pleasant v. State, 01-14-00586-
CR on February 19,2015.
• Completed a rather large and complex State's appeal on State v. Hector
Pella, 14-14-00746-CR on February 11,2015.
• Completed a supplemental brief ordered in Javia Sillqllize Johnson v. State, 01-
14-00185-CR on February 12,2015.
• Assisted in preparing for Oral Arguments on Vincellt Zahorik v. State, 14-13-
00763-CR. Oral Arguments were set for November 17,2014 and reset the
same day. Arguments were held on January 12,2015.
• Is solely responsible for all Post-Conviction Writs of Habeas Corpus for
Galveston County and completed 8 post-conviction writ answers on case
numbers: 11-CR-3078-83-1 (&lIIe1y OWells); 37968-83-2 (Michael Richie); 08-CR-
2835-83-1 (Pedro Cabrera); ll-CR-1177-83-1, ll-CR-1178-83-1, ll-CR-1179-
83-1 (MichaelS hqylle Halls/~); 03-CR-0733-83-4 (Rllssell Kevill TbOmpS011); 01 -
CR-1711-83-2, 01-CR-1712-83-2 (jllall Alberto Deleon); 1O-CR-0325-83-1, 10-
CR-0326-83-1 (Richard Herod); 1O-CR-1217-83-5 (Thomas Florence).
• Was out of state for nearly 2 weeks.
6. The State must also complete its response brief to ClYde Edwin Hedrick v. Slate,
14-14-00378-CR, due on 4/6/2015.
7. The State must also complete its response brief to Cal/ie Inman v. State, 14-14-
00960-CR & 14-14-00961-CR, due on 4/9/2015.
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8. The State must also complete its response brief to liollel Frallk/illv. State, 14-
14-00559-CR & 14-14-00961-CR, due on 4/17/2015.
WHEREFORE, PREMISES CONSIDERED, the State respectfully requests
that this Court of Appeals extend the time to file the State's brief until May 9, 2015.
Respectfully submitted,
JACK ROADY
CRIMINAL DISTRICT ATTORNEY
GALVESTON COUNTY, TEXAS
lsi Rebecca Klare1l
REBECCA KLAREN
Assistant Criminal District Attorney
600 59'h 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
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CERTIFICATE OF COMPLIANCE
The undersigned Attorney for the State certifies this brief is computer generated,
and consists of 423 words.
Is I Rebecca Kiarell
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 James Bennett, Attorney for Appellant, at
jamesmbcnnctt@sbcglobal.nct or 14351 County Road 185, Alvin, TX 77511, on
March 9, 2015.
lsi Rebecca Klare/I
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 March 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"
~e:z:~~
REBECCA KLAREN
Assistant Criminal District Attorney
Galveston County, Texas
SWORN TO AND SUBSCRIBED before me on March 9, 2015.
l::~
.. NOTARY PUBLIC in and for
the State of Texas
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OONAUlUOUNDS
'i t MY COMMISSION EXPIRES
... . Illy 15,2018
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Joshua Dwayne Bledsoe v. State
Combined Opinion