ACCEPTED
01-15-00297-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
12/30/2015 12:22:38 PM
CHRISTOPHER PRINE
CLERK
NO.Ol-15-00297-CR
PRENTIS RAY VENZANT, IN THE COURT OF APPEALS
FILED IN
APPELLANT 1st COURT OF APPEALS
HOUSTON, TEXAS
12/30/2015 12:22:38 PM
v. FIRST SUPREME JUDICIAL
CHRISTOPHER A. PRINE
DISTRICT Clerk
THE STATE OF TEXAS,
APPELLEE HOUSTON, TEXAS
MOTION FOR EXTENSION OF TIME TO
FH.E 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 Vehicle, and was sentenced
on 3/27/2015. The trial case was styled as State of Texas v. Prentis Roy Venzant, in
the 212'h Judicial District Court of Galveston County, Texas, Cause No. 14-CR-
2810. Appellant filed timely Notice of Appeal. The Appellant's brief was filed with
this Court on 11/30/2015.
2. The present due date for filing the State's briefis 12/30/2015.
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 2/29/2016.
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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• Completed a State's Response Brief in Robert Rollins v. State, 01-14-
00769-CRon 11/16/2015.
• Completed a Petition for Discretionary Review in Eric Greer v. State,
01-14-00033-CR, on 11/19/2015.
• Completed a State's Response Brief in Gary James Cox v. State, Nos.
01-15-00220-CR, 01-15-00221-CR, 01-15-00222-CR on
12/14/2015.
• Filed answers, responses, agreed orders, and appeared in court for
hearings or other docket matters on numerous expunctions and
nondisclosures, and misidentification expunctions.
6. The State must also complete its response brief to Brian DamellJohnson II. Stale,
01-15-00101-CR, due on December 30,2015.
7. The State must also complete its response brief to Brandon Marlo Miller v. State,
14-15-00293-CR, due on January 19,2016.
8. The State must also complete its response brief to Gregory Charles Hurst v. State,
14-15-00539-CR, due on February 1, 2016.
9. The State must also complete its response brief to Altin Pinkney v. State, 14-15-
00428-CR, due on February 12, 2016.
10. The State must also complete its response brief to Michael Grimm v. State, 14-
15-00284-CR, due on February 16,2016.
WHEREFORE, PREiYIISES CONSIDERED, the State respectfully requests
that this Court of Appeals extend the time to file the State's brief until February 29,
2016.
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Respectfully submitted,
JACK ROADY
C ALDISTRICT ATTORNEY
G ON COUNTY TEXAS
riminal District Attorney
Street, Suite 1001
Galveston County, Texas 77551
Tel.(409)766-2355, fax (409)766-2290
State Bar Number: 24062850
allison.lindblade@co.ga!vcston.rx.us
CERTIFICATE OF COMPLIANCE
The undersigned Attorney for the State c .fies this brief is computer generated,
and consists of 345 words.
CERTIFICATE OF SERVICE
The undersigned attorney for the State certifies that a copy of the above motion
was emailedl eFiledtoTadNelson,Attorney for Appellant, at
tad@thcnclsonfum.com on December 30, 2015.
l!sil;.e!fitQllfuinal District Attorney
Galveston County, Texas
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AFFIDAVIT
THE STATE OF TEXAS
COUNTY OF GALVESTON
Before me, the undersigned authority, on December 30, 2015, appeared Allison
Lindblade, who by me duly sworn did depose and state on oath the following:
"I, Allison Lindblade, 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 th.<;re~s true and correct."
DBLADE
s t Criminal District Attorney
Galveston County, Texas
SWORN TO AND SUBSCIUBED before me on December 30, 2015.
~ &~\1,w-
NOTARY PUBLIC in and for
the State of Texas
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