CASE NO. 14-14-00513-CR 

STATE OF TEXAS § IN THE FOURTEENTH 

VS. § COURT OF APPEALS 

PEDRO REYES TREJO § SITTING IN HOUSTON I TEXAS 

SECOND MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF 

TO THE HONORABLE JUSTICES OF SAID COURT: 

Now comes PEDRO REYES TREJO, appellant in the 

above-styled and numbered cause, and moves this Court to 

grant his Second Motion to Extend Time to file 

Appellant's Brief, pursuant to Rule 74(k) of the Texas 

Rules of Appellate Procedure, and for good cause shows 

the following: 

I.

This case is on appeal from the 506TH Judicial 

District Court of Waller County, Texas. 

II.

The case below was styled the STATE OF TEXAS V. PEDRO 

REYES TREJO and numbered 04-06-11756. 

III.

On November 22, 2010 Appellant was found guilty by a 

and sentence was imposed at 16 years in the 

Institutional Division of the Texas Department of 

Criminal Justice by the Honorable Jeff Steinhauser, 

Judge in the 155th District Court of Waller County. 

ACCEPTED

14-14-00513-CR

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

4/17/2015 8:24:26 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 4/17/2015 8:24:26 PM CHRISTOPHER A. PRINE Clerk
IV. 

Thereafter Appellant appealed and the Court of 

Appeals Affirmed on October 17, 2011. On November 12, 

2013 Appellant filed his Motion for Court Order to 

Appoint a Second Expert for DNA Testing. Said Motion 

was denied and appeal was had. Subsequently said Appeal 

was abated and a hearing had on the status of the case 

and for appointment of an attorney. On December 31, 

2014 the appeal was reinstated. 

V.

One other brief extension has been requested and 

granted. That extension of time of 60 days was from the 

date the brief was due to March 30, 2015. Appellant 

timely files this extension motion within 15 days of 

said date. 

VI.

Appellant's counsel now requests an extension of time 

to May 10, 2015, for reasons that follow. 

VII.

Counsel has been unable to complete Appellant's 

Brief within the required time period. Appellant relies 

on the following facts as good cause for his requested 

extension of the time for filing: 

0 I_uoLu or some other individual. 

Given the seriousness of this matter and Counsel's 

limited knowledge of the proceeding he is forced to 

rely on that record and the Appellant. Further, counsel 

has been set for the following court matters in the 

month of March when the brief was due to today's date: 

3- 3 - 15 -ACD- CEVALLOS,CAMPBELL,OSGOOD,BURGER,SMITH, 

BLACKBURN, MARTIN 

3 - 5 - 15 -ACCL-FLORES,POWERS 

3-9-15-ACD-PICKRON MURDER TRIAL 

WCD-VICKERS TRIAL 

3 - 16 - 15-ACCL-JUV-SANDERS TRIAL - DISMISSED 

3 - 19 - 15 -ACCL-MARQUEZ,HILL,RIVAS,HARRIS,MCKEY 

3-24-1 5 -ACD- BURGER,TARVER,CAMPBELL,KELLOW,D-CAMACHO, 

C - CAMACHO,BYRD,COFFMAN-HARRIS,ANDERS,SMITH 

WCD-DANIELS,MCFARLAND 
[ LEGEND ] 

ACD-AUSTIN COUNTY DISTRICT COURT (155TH) 

WCD-WALLER COUNTY DISTRICT COURT (506TH)] 

ACCL-WALLER COUNTY COURT AT LAW 

COLCOD-COLORADO COUNTY DISTRICT COURT (2ND 25TH) 

WHEREFORE, PREMISES CONSIDERED, appellant prays that 

this Court grant this Second Motion To Extend Time to 

File Appellant's Brief until May 5, 2015 for 

such other and further relief as this Court may 

deem appropriate. 

Respectfully submitted, 

CALVIN GARVIE 

POST OFFICE BOX 416 

BELLVILLE, TEXAS 77418 

PH (979) 865-5456 

FAX (832)383-8814 

Email texattycg@aol.com 

BY: /s/ Calvin Garvie 

STATE BAR NO.:07714300 

ATTORNEY FOR APPELLEANT 
CERTIFICATE OF WORD COUNT 

I hereby certify that this Second Motion, it's affidavit 

and certificates contains a total of words. 

/s/ Calvin Garvie 

CERTIFICATE OF SERVICE 

I hereby certify that a copy of the above and foregoing 

Second Motion To Extend Time to File Appellant's Brief 

was sent by mailed, faxed, e-mailed or hand-delivered to 

the Waller County District Attorney's Office on April 

17, 2015. . 

/s/ Calvin Garvie 
STATE OF TEXAS 

COUNTY OF WALLER 

AFFIDAVIT 

BEFORE ME, the undersigned authority, on this day 

personally appeared CALVIN GARVIE, who after being duly 

sworn stated: 

"I am the attorney for the appellant in the 

above numbered and entitled cause. I have read 

the foregoing Second Motion To Extend Time to 

File Appellant's Brief and swear that all of 

the allegations of fact contained therein are 

true and correct to the best of_illy knowledge." ) /e2 LA, 

CAL IN GARVIE 

Affiant 

SUBSCRIBED AND SWORN TO BEFORE ME on April 17, 

2015, to certify which witness my hand and seal of 

office. 

Nota y Public, State of Texas