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