Garza, Rodolfo

• Court: Court of Appeals of Texas
• Decided: October 13, 2015
• Docket: WR-82,771-02
• Status: Published

Opinion

WR-82,771-01,02,03,04,05 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 10/13/2015 3:58:48 PM Accepted 10/13/2015 4:47:16 PM NOS. WR-82,771-01, WR-82,771-02, WR-82,771-03, WR-82,771-04 & WR-82,771-05 ABEL ACOSTA CLERK EX PARTE § IN THE COURT OF CRIMINAL RECEIVED § APPEALS COURT OF CRIMINAL APPEALS § 10/13/2015 RODOLFO GARZA § OF TEXAS ABEL ACOSTA, CLERK

APPLICANT’S FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME

TO THE HONORABLE JUDGES OF SAID COURT:

Applicant Rodolfo Garza (hereinafter referred to as “Applicant”), by through his newly

retained undersigned counsel, respectfully submits this, his First Unopposed Motion for

Extension of Time, and in support thereof would show this Court as follows:

I.

Applicant recently retained the undersigned to represent him in the above-styled

proceeding.

II.

On June 17, 2015, this Court entered an Order setting forth deadlines by which the trial

court was to take certain actions in this matter, as described more fully therein, within ninety (90)

days and one hundred and twenty (120) days, respectively, of that Order,

III.

The undersigned requires at least thirty (30) days to properly investigate this matter,

including, but not limited to reviewing offense reports, plea papers, sentencing transcripts, and

related materials concerning the numerous convictions at issue in this case, interviewing trial

counsel, and reviewing all pleadings and affidavits that have previously been filed. IV.

Consequently, the undersigned respectfully requests that this Court issue a new Order to

replace that of June 17, 2015, setting forth new deadlines of ninety (90) and one hundred (120)

days for the trial court to take the actions described more fully therein.

V.

The undersigned conferred with Matagorda County District Attorney Steven Reis

concerning the relief requested in this motion, and learned that the State of Texas is not opposed

to same. Moreover, this is Applicant’s first request for such an extension of time.

WHEREFORE, PREMISES CONSIDERED, Applicant Rodolfo Garza respectfully

requests that this unopposed motion be, in all things, granted, and that this Court enter a new

Order setting forth new deadlines to replace those previously described in this Court’s Order of

June 17, 2015.

Respectfully submitted,

LAW OFFICES OF D. CRAIG HUGHES

/D. Craig Hughes ____________________________________ D. CRAIG HUGHES State Bar No. 10211025 7322 Southwest Freeway - Suite 1100 Houston, Texas 77074 (713) 535-0683 (713) 981-3805 (FAX) dcraighughes @msn.com (email) ATTORNEY FOR APPLICANT RODOLFO GARZA

THE LAW OFFICE OF KYLE VERRET, PLLC

/ J. Kyle Verret ___________________________ J. KYLE VERRET State Bar No. 24042932 11200 Broadway, Suite 2743 Pearland, TX 77584 Phone / Fax: (281) 764-7071 2029 Strand, Suite 3, Galveston, TX 77550 Phone / Fax: (409) 515-5004 Email: kyle@verretlaw.com ATTORNEY FOR APPLICANT RODOLFO GARZA

CERTIFICATE OF SERVICE

The undersigned certifies that he forwarded a true and correct of the foregoing motion via facsimile transmission to Matagorda County District Attorney Steven Reis on this the 13 th day of October, 2015.

/D. Craig Hughes ____________________________________ D. Craig Hughes