WR-82,771-01,02,03,04,05
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 10/13/2015 3:58:48 PM
Accepted 10/13/2015 4:47:16 PM
NOS. WR-82,771-01, WR-82,771-02, WR-82,771-03, WR-82,771-04 & WR-82,771-05 ABEL ACOSTA
CLERK
EX PARTE § IN THE COURT OF CRIMINAL
RECEIVED
§ APPEALS COURT OF CRIMINAL APPEALS
§ 10/13/2015
RODOLFO GARZA § OF TEXAS ABEL ACOSTA, CLERK
APPLICANT’S FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME
TO THE HONORABLE JUDGES OF SAID COURT:
Applicant Rodolfo Garza (hereinafter referred to as “Applicant”), by through his newly
retained undersigned counsel, respectfully submits this, his First Unopposed Motion for
Extension of Time, and in support thereof would show this Court as follows:
I.
Applicant recently retained the undersigned to represent him in the above-styled
proceeding.
II.
On June 17, 2015, this Court entered an Order setting forth deadlines by which the trial
court was to take certain actions in this matter, as described more fully therein, within ninety (90)
days and one hundred and twenty (120) days, respectively, of that Order,
III.
The undersigned requires at least thirty (30) days to properly investigate this matter,
including, but not limited to reviewing offense reports, plea papers, sentencing transcripts, and
related materials concerning the numerous convictions at issue in this case, interviewing trial
counsel, and reviewing all pleadings and affidavits that have previously been filed.
IV.
Consequently, the undersigned respectfully requests that this Court issue a new Order to
replace that of June 17, 2015, setting forth new deadlines of ninety (90) and one hundred (120)
days for the trial court to take the actions described more fully therein.
V.
The undersigned conferred with Matagorda County District Attorney Steven Reis
concerning the relief requested in this motion, and learned that the State of Texas is not opposed
to same. Moreover, this is Applicant’s first request for such an extension of time.
WHEREFORE, PREMISES CONSIDERED, Applicant Rodolfo Garza respectfully
requests that this unopposed motion be, in all things, granted, and that this Court enter a new
Order setting forth new deadlines to replace those previously described in this Court’s Order of
June 17, 2015.
Respectfully submitted,
LAW OFFICES OF D. CRAIG HUGHES
/D. Craig Hughes
____________________________________
D. CRAIG HUGHES
State Bar No. 10211025
7322 Southwest Freeway - Suite 1100
Houston, Texas 77074
(713) 535-0683
(713) 981-3805 (FAX)
dcraighughes @msn.com (email)
ATTORNEY FOR APPLICANT
RODOLFO GARZA
THE LAW OFFICE OF
KYLE VERRET, PLLC
/ J. Kyle Verret
___________________________
J. KYLE VERRET
State Bar No. 24042932
11200 Broadway, Suite 2743
Pearland, TX 77584
Phone / Fax: (281) 764-7071
2029 Strand, Suite 3, Galveston, TX 77550
Phone / Fax: (409) 515-5004
Email: kyle@verretlaw.com
ATTORNEY FOR APPLICANT
RODOLFO GARZA
CERTIFICATE OF SERVICE
The undersigned certifies that he forwarded a true and correct of the foregoing motion via
facsimile transmission to Matagorda County District Attorney Steven Reis on this the 13 th day of
October, 2015.
/D. Craig Hughes
____________________________________
D. Craig Hughes