### NO. 01-15-00220-CR, 01-15-00221-CR, 01-lS-00222-CR 

### GARYJAMES COX, APPELLANT INTHE COURT OF APPEALS 

### V. THE STATE OFTEXAS, APPELLEE FIRST SUPREME DISTRICT HOUSTON, TEXAS MOTION FOREXTENSION OFTIMETO FII.E 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 AGGRAVATED SEXUAL ASSAULT OF A CHILD WITH ENHANCEIvIENT, SEX OFFENDERS DUTY TO REGISTER LIFE/ANNUALLY, ATI'EMPT TO COMMIT SEXUAL PERFORMANCE OF A CHILD WITH ENHANCEMENT, and was sentenced on 2/4/2015. The trial case was styled as State 

## ofTexas v. GaryJames Cox, in the 122nd Judicial District Court of Galveston County, Texas, Cause No. 13-CR -0183, 13-CR-0184, 14-CR3651. Appellant filed timely Notice ofAppeal. The Appellant'S briefwas filed with this Court on 8/7/2015. 2. The present due date for filing the State's briefis 10/9/2015. 3. This is the State's second motion for extension oftime to file its brief. 4. The State requests an extension to file its briefon orbefore 12/9/2015. 

## I 1 ACCEPTED 01-15-00220-CR FIRST COURT OF APPEALS

HOUSTON, TEXAS 10/9/2015 11:32:15 AM CHRISTOPHER PRINE

CLERK5. The State requests this extension not for delay but because during the last sixty days, the undersigned attorney for the State: • Completed a State's response brief on Writ of Mandamus in 

### III Re Alltonio Sepeda, 14-15-00288-CV, on 8/13/2015; and State's proposed Findings ofFacts and Conclusions ofLaw regarding the same line ofcases on 9/22/2015. • Attended a IDCAA Legislative update on 8/20/2015. • Completed a State's response brief in 

### Ralph Garcia v. State, 01-14- 00954-CRon 9/11/2015. • Completed an Ander's Response in

### Allthof!y Bradford v. 

### State, 14-15- 00201-CR& 14-15-00202-CR, on 9/21/2015. • Responded to 

### Appellallt/ Deftlldallt's Motiollfor the COllrt to Declare Applicallt is a Victim 

## of Idmtity Theft alld Applicallt Reqllestif'!, Declaration thatApplication is a Victim 

## of Idtfltity Theft in Cause No. MD-322640; No. 14-13-00763-CR 

### Vil/tefit Zahorik v . State in County Court ofLaw No. 2, Galveston County; and argued at the hearing on September 29, 2015. • Filed answers, responses, agreed orders, and appeared in court for hearings or docket on approximately 60 expunctions and nondisclosures, and misidentification expunctions. • Completed a post-conviction writ answer on a capital life writ, case numbers: 98-CR-0358-83-3, 98-CR-0359-83-3, 98-CR-0360-83-3, 98-CR-0361-83-3, 98-CR-0362-83-3 

### (Keith St Allbill); researched issues for supplement answer; and will file supplemental answer today. 6. The State must also complete its response briefto 

### RobertRol/ills v. State, 01-14- 00768-CR, due on October 26, 2015.

2WHEREFORE. PREMISES CONSIDERED, the State respectfully requests that this Court of Appeals extend the time to file the State's brief until December 9, 2015. Respectfully submitted, JACK 

### 0 Y CruN

### ~ISTRICT ATTORNEY
, N COUNTY,TE.."'{AS 

# J I INDBLADE Ascsistam Criminal DistrictAttorney 600 59th Street, Suite 1001 Galveston County, Texas 77551 Tel.(409)766-2355, fax (409)766-2290 State Bar Number: 24062850 allison.lindblade@co.g.alveston.t:x.us CERTIFICATE OF COMPLIANCE The undersigned Attorney for the State certifies this briefis computer generated, and consists of416 words.

LINDBLADE Assistant Criminal DistrictAttorney Galveston County, Texas

3CERTIFICATE OF SERVICE The undersigned attorney for the State certifies that a copy ofthe above motion was emailed/eFiledtoJoeiBennett.AttomeyforAppellant.at joel@searsandbennett.com on October 9, 2015. is 

### riminal District Attorney eston County, Texas

4AFFIDAVIT THE STATE OF TEXAS COUNTYOF GALVESTON Before me, the undersigned authority, on October 9, 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 information contained therein is true and correct." 

### '\

,llll.nu:al DistrictAttorney Galveston County, Texas
SWORN TO AND SUBSCRIBED before me on October 9, 2015.

# ~G**~** NOTARY PUBLIC in and for the State ofTexas

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