White, Garcia Glen

Opinion

WR-48,152-08 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 6/1/2016 12:21:15 PM June 1, 2016 Accepted 6/1/2016 12:33:29 PM ABEL ACOSTA No. WR-48,152-08 CLERK ♦ In the Court of Criminal Appeals At Austin ♦ Ex Parte GARCIA GLEN WHITE Applicant ♦ On Application for Writ of Habeas Corpus From the 180th District Court of Harris County, Texas No. 723847 ♦

APPLICANT’S MOTION FOR EXTENSION IN TIME IN WHICH TO CORRECT DEFICIENCIES IN MAY 24, 2016 RESPONSE

♦

TO THE HONORABLE JUSTICES OF THE COURT OF CRIMINAL APPEALS OF TEXAS:

COMES NOW, the Applicant, Garcia Glen White, by and through his attorneys

of record, Patrick F. McCann and Mandy Miller, and respectfully moves this

Honorable Court to extend the time for filing his Response to this Court’s Order of

March 23, 2016, up to and including June 1, 2016. In support of such motion, the

Applicant would show the Court the following:

(1) After receiving one extension in time up to and including May 24,

2016, in which to file a Response worthy of this Court’s attention, the Applicant

timely filed his Response on May 24, 2016.

1|Page (2) The undersigned counsel were advised telephonically by the Clerk of

this Court on June 1, 2016, that the Applicant’s Response was deficient and had

been rejected for filing because of the unintended omission of the Certificate of

Compliance with respect to the word count of the Response.

(3) The undersigned have corrected this deficiency and,

contemporaneously with the filing of this motion for extension in time, have re-

submitted the corrected Response.

(4) The undersigned apologize to both the Court and its Clerk for any

inconvenience this omission may have caused, and make assurances that steps

have been taken to ensure that this does not happen again.

PRAYER

WHEREFORE, PREMISES CONSIDERED, the Applicant prays that this Honorable

Court will, in all things, GRANT this motion, and permit the filing of the

Applicant’s corrected Response to this Court’s March 23, 2016 Order, and that the

Court further GRANT any additional relief to which the Applicant may be legally

and justly entitled.

DATED this 1ST day of June, 2016.

2|Page Respectfully submitted,

PATRICK MCCANN State Bar No: 00792680 writlawyer@justice.com

MANDY MILLER State Bar No: 24055561 mandy@mandymillerlegal.com

909 Texas Ave., Ste. 205 Houston, TX 77002 (713) 223-3805 Fax (713) 226-8097

Attorneys for the Applicant GARCIA GLEN WHITE

3|Page CERTIFICATE OF SERVICE

Applicant has sent a copy of the foregoing instrument to counsel for the

State of Texas at the following electronic mail addresses on this 1st day of June,

2016:

Lynn Hardaway Harris County Assistant District Attorney hardaway_lynn@dao.hctx.net

Lori DeAngelo Harris County Assistant District Attorney deangelo_lori@dao.hctx.net

PATRICK MCCANN

MANDY MILLER

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