Carlos Gallegos-Piedra v. State

ACCEPTED 14-14-01025-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 3/23/2015 3:17:05 PM CHRISTOPHER PRINE CLERK No. 14-14-01025-CR 14-14-01026-CR 14-14-01027-CR FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS In the Fourteenth Court of Appeals, 3/23/2015 3:17:05 PM Houston, Texas CHRISTOPHER A. PRINE Clerk CARLOS GALLEGOS-PIEDRA Appellant v. THE STATE OF TEXAS Appellee Appellant’s Second Motion for Extension of Time to File Brief Respectfully Submitted by: Joseph Kyle Verret THE LAW OFFICE OF KYLE VERRET, PLLC Counsel for Appellant TBN: 240429432 11200 Broadway, Suite 2743 Pearland, Texas 77584 Phone: 281-764-7071 Fax: 281-764-7071 Submitted: Email: kyle@verretlaw.com March 23, 2015 No. 14-14-01025-CR 14-14-01026-CR 14-14-01027-CR In the Fourteenth Court of Appeals, Houston, Texas CARLOS GALLEGOS-PIEDRA Appellant v. THE STATE OF TEXAS Appellee Appellant’s Second Motion for Extension of Time to File Brief Comes now, Appellant, by and through his undersigned counsel, in the above styled cause and moves this Honorable Court to extend the time for the filing of Appellant's Brief. Per Texas Rule of Appellate Procedure 10.5(b), Appellant provides the following: Current Deadline for Filing: March 23, 2015 Length of Extension Sought: Thirty (30) days (to April 22, 2015) Number of Previous Extensions Granted: One. Basis for Extensions: Appellant's counsel is a solo practitioner with a busy criminal and juvenile defense caseload, which requires regular appearances in court on the part of counsel. In the thirty days since the last motion to extend time to file brief, Appellant has completed and filed an appellant brief in appeal number 01-14-00895-CR, which is presently due to be filed with the First Court of Appeals on March 13, 2015. The record in these causes is over 400 pages. Counsel needs additional time to review the record and prepare a cogent and succinct brief. PRAYER FOR RELIEF For the reasons set forth above, Appellant requests that this Court grant this Appellant’s First Motion to Extend Time to File Appellant’s Brief and extend the Deadline for Filing the Appellant’s Brief up to and including April 22, 2015. Appellant prays all other relief to which he may be entitled. Respectfully submitted, /s/ Joseph Kyle Verret Joseph Kyle Verret THE LAW OFFICE OF KYLE VERRET, PLLC Counsel for Appellant TBN: 240429432 11200 Broadway, Suite 2743 Pearland, Texas 77584 Phone: 281-764-7071 Fax: 281-764-7071 Email: kyle@verretlaw.com Certificate of Service I certify that a true and correct copy of the foregoing Appellant's Second Motion for Extension of Time to File Brief was served on this 23rd day of March, 2015, on the Counsel for the Appellee, David Bosserman, at the Brazoria County Criminal District Attorney’s Office by e-service through electronic filing. /s/ Joseph Kyle Verret Joseph Kyle Verret TBN: 2402932