Carlos Gallegos-Piedra v. State

Opinion

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