Joshua Dwayne Bledsoe v. State

• Court: Court of Appeals of Texas
• Decided: March 9, 2015
• Docket: 14-14-00380-CR
• Status: Published

Opinion

ACCEPTED 14-14-00380-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 3/9/2015 9:27:43 AM CHRISTOPHER PRINE CLERK

NO. 14-14-00380-CR

JOSHUA DWAYNE BLEDSOE, IN THE COURT OF APPEALS FILED IN APPELLANT 14th COURT OF APPEALS HOUSTON, TEXAS 3/9/2015 9:27:43 AM v. FOURTEENTH CHRISTOPHER SUPREME A. PRINE JUDICIAL DISTRICT Clerk

THE STATE OF TEXAS, APPELLEE HOUSTON, TEXAS

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 unauthorized use of a motor vehicle, and was sentenced on 4/4/2014. The trial case was styled as State of Texas v. Joshlla Dwcryne Bledsoe, in the 405th Judicial District Court of Galveston County, Texas, Cause No. 09CR0075. Appellant filed timely Notice of Appeal. The Appellant's brief was filed with this Court on 2/6/2015.

2. The present due date for filing the State's brief is 3/9/2015.

3. This is the St.'lte's first motion for extension of time to file its brief.

4. The State requests an extension to file its brief on or before 5/9/2015.

5. The State requests this extension not for delay but because during the last sixty

1 days, the undersigned attorney for the State:

• Completed the State's response brief on Fahd Tallash v. State, 14-14-00463-CR on March 6, 2015.

• Completed the State's response brief on Bralldoll EVOIIS v. State, 01-13-00345- CR on February 23, 2015.

• Completed the State's response brief on Elijah Pleasant v. State, 01-14-00586- CR on February 19,2015.

• Completed a rather large and complex State's appeal on State v. Hector Pella, 14-14-00746-CR on February 11,2015.

• Completed a supplemental brief ordered in Javia Sillqllize Johnson v. State, 01- 14-00185-CR on February 12,2015.

• Assisted in preparing for Oral Arguments on Vincellt Zahorik v. State, 14-13- 00763-CR. Oral Arguments were set for November 17,2014 and reset the same day. Arguments were held on January 12,2015.

• Is solely responsible for all Post-Conviction Writs of Habeas Corpus for Galveston County and completed 8 post-conviction writ answers on case numbers: 11-CR-3078-83-1 (&lIIe1y OWells); 37968-83-2 (Michael Richie); 08-CR- 2835-83-1 (Pedro Cabrera); ll-CR-1177-83-1, ll-CR-1178-83-1, ll-CR-1179- 83-1 (MichaelS hqylle Halls/~); 03-CR-0733-83-4 (Rllssell Kevill TbOmpS011); 01 - CR-1711-83-2, 01-CR-1712-83-2 (jllall Alberto Deleon); 1O-CR-0325-83-1, 10- CR-0326-83-1 (Richard Herod); 1O-CR-1217-83-5 (Thomas Florence).

• Was out of state for nearly 2 weeks.

6. The State must also complete its response brief to ClYde Edwin Hedrick v. Slate, 14-14-00378-CR, due on 4/6/2015.

7. The State must also complete its response brief to Cal/ie Inman v. State, 14-14- 00960-CR & 14-14-00961-CR, due on 4/9/2015. 2 8. The State must also complete its response brief to liollel Frallk/illv. State, 14- 14-00559-CR & 14-14-00961-CR, due on 4/17/2015.

WHEREFORE, PREMISES CONSIDERED, the State respectfully requests that this Court of Appeals extend the time to file the State's brief until May 9, 2015.

Respectfully submitted,

JACK ROADY CRIMINAL DISTRICT ATTORNEY GALVESTON COUNTY, TEXAS

lsi Rebecca Klare1l REBECCA KLAREN Assistant Criminal District Attorney 600 59'h Street, Suite 1001 Galveston County, Texas 77551 Tel.(409)766-2355, fax (409)766-2290 State Bar Number: 24046225 rebecca.klaren@co.galveston.tx.us

3 CERTIFICATE OF COMPLIANCE

The undersigned Attorney for the State certifies this brief is computer generated,

and consists of 423 words.

Is I Rebecca Kiarell REBECCA KLAREN 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 faxed/ emailed/ eFiled / or mailed to James Bennett, Attorney for Appellant, at

jamesmbcnnctt@sbcglobal.nct or 14351 County Road 185, Alvin, TX 77511, on

March 9, 2015.

lsi Rebecca Klare/I REBECCA KLAREN Assistant Criminal District Attorney Galveston County, Texas

4 AFFIDAVIT

THE STATE OF TEXAS

COUNTY OF GALVESTON

Before me, the undersigned authority, on March 9, 2015, appeared Rebecca

Klaren, who by me duly sworn did depose and state on oath the following:

"I, Rebecca Klaren, 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"

~e:z:~~ REBECCA KLAREN Assistant Criminal District Attorney Galveston County, Texas

SWORN TO AND SUBSCRIBED before me on March 9, 2015.

l::~ .. NOTARY PUBLIC in and for the State of Texas

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