### NO. 01-15-00221-CR, 01-15-00222-CR 

### GARYJAMES COX, APPELLANT INTHE COURT OFAPPEALS 

# v. THE STATE OFTEXAS, APPELLEE FIRST SUPREME DISTRICT HOUSTON,TEXAS MOTION FOREXTENSION OFTIMETO FILE STATE'S RESPONSE BRIEF TOTHE HONORABLE COURT OFAPPEALS: JUDICIAL

Now comesJack Roady, Criminal District Attorney ofGalveston 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 ofAppeals as follows: 1. The appellant was convicted of SEX OFFENDER'S FAILURE TO COMPLY, ATTEMPTED SEXUAL PERFORMANCE OF A CHILD, and was sentenced on 2/4/2015. The trial 

### case was styled as State 

### oj Texas v. Gary James Cox, 

### in the 122nd

### Judicial District Court ofGalveston County, Texas, Cause Nos. 13-CR-0184, 14-CR-3561. Appellant filed timely Notice of Appeal. The Appellant's brief was filed with this Court on 8/7/2015. 2. The present due date for filing the State's briefis 9/8/2015. 3. This is the State's first motion for extension oftime to file its brief. 4. The State requested and was granted an extension on the companion case 01-15· 00220-CR to 10/9/2015. The State inadvertendy forgot to request an extension on the two above cases. The State requests the two cases be extended along with the comparuon case. 1 ACCEPTED 01-15-00221-CR FIRST COURT OF APPEALS

HOUSTON, TEXAS 9/14/2015 4:37:03 PM CHRISTOPHER PRINE

CLERK5. The State requests an extension to file its briefon orbefore 10/9/2015. 6. The State requests this extension not for delay butbecause during the last seventyfive days, the undersigned attorney for the State: • Completed a State's response brief in 

### LamarHI/liter v. Slate, 01-14- 00895-CR, on7/7/2015. • Attended a CLEon7/9/2015 and 9/10/2015. • Completed a State's response brief on Writ ofMandamus in 

### In Re 

### Alllollio Sepeda, 14-15-00288-CV, on 8/13/2015. • Attended aTDCAA Legislative update on 8/20/2015. • Completed a State's response brief in 

### Ralph Garda v. Slate, 01-14- 00954-CRon 9/11/2015. • Handled 72 expunctions and nondisclosures, and misidentification expunctions. • Completed post-conviction writ answers on case numbers: 11-CR

### 0345-83-1 (Mario Meza); 98-CR-0358-83-3, 98-CR-0359-83-3, 98- CR-0360-83-3, 98-CR-0361-83-3, 98-CR-036Z-83-3 

### (Keith SI. AI/bill). 7. The State must also complete its response brief

### toA,ltho,!yBradfordv. Siale, 14- 15-00Z01-CR & 14-15-0020Z-CR, due on SeptemberZ1, 2015. 8. The State must also complete its response briefto 

### RobertRollills v. Slale,01-14- 00768-CR, due on October 26, 2015. WHEREFORE, PREMISES CONSIDERED, the State respectfully requests that this Court ofAppeals extend the time to file the State's briefuntil October9, 2015.

2Respectfully submitted, JACKRO Y C DISTRICT G NCO
Assistant Criminal District Attorney 600 59th Street, Suite 1001 Galveston County, Texas 77551 Tel.(409)766-2355, fax (409)766-2290 State Bar Nwnber: 24062850 a1lison.lindblade@co.ga!vcston.tx.us 

### CERTIFICATE OF COMPLIANCE The undersigned Attorney for the State certifies this briefis computergenerated, and consists of364words.
Assis riminal DistrictAttorney eston County,Texas 

### CERTIFICATE OF SERVICE The undersigned attorney for the State certifies that a copy ofthe above motion was faxed/ emailed/ eFiled / or mailed to Joel Bennett, Attorney for Appellant, at jocl@scarsandbcnnctt.com on September 14, 2 15.

3 . tant Criminal DistrictAttorney Galveston County, Texas

### AFFIDAVIT THE STATE OFTEXAS COUNTY OF GALVESTON Before me, the undersigned authority, on September 14, 2015, appeared Allison Lindblade, who by me duly sworn did depose and state on oath the following: "I, Allison Lindblade, Attorney for the State of Texas, have read the Motion for Extension ofTime to File the State's Brief, and swear that the infonnation contained therein is true and correct"

riminal DistrictAttorney veston County, Texas
SWORN TO AND SUBSCRIBED before me on September 14, 2015.

NOTARYPUBLICin and for the State ofTexas

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