ACCEPTED
01-14-00700-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
11/12/2015 8:20:58 AM
CHRISTOPHER PRINE
CLERK
NO.Ol-14-00700-CR
THERRELL DEWAYNE FELDER, IN THE COURT OF APPEALS
FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
APPELLANT 11/12/2015 8:20:58 AM
FIRST SUPREME JUDICIAL
CHRISTOPHER A. PRINE
v. DISTRICT Clerk
THE STATE OF TEXAS, HOUSTON, TEXAS
APPELLEE
UNOPPOSED 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 FORGERY, and was sentenced on 7/18/2014.
The trial case was styled as Siale of Texas v. Themli Dewayne Felder, in the 122nd
Judicial District Court of Galveston County, Texas, Cause No. 14-CR-0283.
Appellant filed timely Notice of Appeal. The Appellant's brief was filed with this
Court on 8/12/2015.
2. The present due date for filing the State's briefis 11/12/2015.
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 11/30/2015.
5. The State requests this extension not for delay but because during the last thirty
days, the undersigned attorney for the State:
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• Has an active daily docket while working on the appeal.
• Sdected a jury on November 9, 2015 in case number 15-CR-0262 in
State v. Joshua Marshall. The defendant is charged with a first
degree- Possession of a Controlled Substance with Intent to Deliver
Heroin. He was found guilty on November 10, 2015. The
punishment phase of the trial is to begin this morning.
WHEREFORE, PREMISES CONSIDERED, the State respectfully requests
that this Court of Appeals extend the time to file the State's brief until November 30,
2015.
Respectfully submitted,
JACK ROADY
CRIMINAL DISTRICT ATIORNEY
GALVESTON COUNTY, TEXAS
lsI T. PhiliP Washington
T. PHll..1P WASHINGTON
Assistant Criminal District Attorney
600 59'h Street, Suite 1001
Galveston County, Texas 77551
Td.(409)766-2355, fax (409)766-2290
State Bar Number: 24068406
tirrell. washington@co.galvcston.tx.us
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CERTIFICATE OF COMPLIANCE
The undersigned Attorney for the State certifies this brief is computer generated,
and consists of 250 words.
lsI T. Philip Washington
T. PHILIP WASHINGTON
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/eFiledtoZachMaloney.AttorneyforAppellant.at
zachmaloney@gmail.com on November 12, 2015.
lsI T. Philip Washingtoll
T. PHILIP WASHINGTON
Assistant Criminal District Attorney
Galveston County, Texas
CERTIFICATE OF CONFERENCE
The office of the undersigned attorney has contacted Zach Maloney, attorney for
Appellant, on November 6, 2015, and confirmed that Zach Maloney is unopposed to
the State's second motion to extend time to file State's brief.
lsI T. Philip Washington
T. PHILIP WASHINGTON
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 November 12, 2015, appeared T.
Philip Washington, who by me duly sworn did depose and state on oath the following:
"I, T. Philip Washington, 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."
T. PHILIP WASHINGTON
Assistant Criminal District Attorney
Galveston County, Texas
SWORN TO AND SUBSCRIBED before me on November 12, 2015.
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