### NO.Ol-14-00700-CR THERRELLDEWAYNE FELDER, INTHE COURT OFAPPEALS APPELLANT 

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THE STATE OFTEXAS, APPELLEE FIRST SUPREME DISTRICT HOUSTON, TEXAS

UNOPPOSED 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 FORGERY, and was sentenced on 7/18/2014. The trial case was styled as 

### Siale 

## ofTexas v. Themli Dewayne Felder, in 

### the 122nd Judicial District Court of Galveston County, Texas, Cause No. 14-CR-0283. Appellant filed timely Notice ofAppeal. The Appellant's briefwas filed with this Court on 8/12/2015. 2. The present due date for filing the State's briefis 11/12/2015
. 3. This is the State's second motion for extension oftime to file its brief. 4. The State requests an extension to file its briefonor before 11/30/2015. 5
. The State requests this extension not for delay but because during the last 

### thirty days, the undersigned attorney for the State: 1 ACCEPTED 01-14-00700-CR FIRST COURT OF APPEALS

HOUSTON, TEXAS 11/12/2015 8:20:58 AM CHRISTOPHER PRINE

CLERK• Has an active daily docket while working on the appeal.
• Sdected a

### jury on November 9, 2015 in case number 15-CR-0262 in State v. Joshua Marshall. The defendant is charged with a first degree- Possession ofa Controlled Substance with Intent to Deliver Heroin. He was found guilty on November 10, 2015. The punishmentphase ofthe trial is to begin this morning. WHEREFORE, PREMISES CONSIDERED, the State respectfully requests that this Court ofAppeals extend the time to file the State's briefuntil November 30, 2015. Respectfully submitted, JACK ROADY CRIMINAL DISTRICTATIORNEY GALVESTON COUNTY,TEXAS



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### T. PhiliP Washington T. PHll..1P WASHINGTON Assistant Criminal DistrictAttorney 600 59'h Street, Suite 1001 Galveston County, Texas 77551 Td.(409)766-2355, fax (409)766-2290 State Bar Number: 24068406 tirrell.washington@co.galvcston.tx.us

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### CERTIFICATE OF COMPLIANCE The undersigned Attorney for the State certifies this briefis computer generated, and consists of250 words. 

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### T. Philip Washington T. PHILIPWASHINGTON Assistant Criminal District Attorney Galveston County, Texas 

### CERTIFICATE OF SERVICE The undersigned attorney for the State certifies that a copy ofthe above motion
was emailed/eFiledtoZachMaloney.AttorneyforAppellant.at zachmaloney@gmail.com on November 12, 2015. 

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### T. Philip Washingtoll T. PHILIP WASHINGTON Assistant Criminal District Attorney Galveston County, Texas


### CERTIFICATE OF CONFERENCE The office ofthe undersigned attorney has contacted Zach Maloney, attorney for Appellant, on November 6, 2015, and confirmed that Zach Maloney is unopposed to the State's second motion to extend time to file State's brief.

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### T. Philip Washington T. PHILIPWASHINGTON Assistant Criminal District Attorney Galveston County, Texas

### AFFIDAVIT THE STATE OF TEXAS
COUNTY OF GALVESTON
Before me, the undersigned authority, on November 12, 2015, appeared T. Philip Washington, who by me duly sworn did depose and state on oath the following: "I, T. Philip Washington, Attorney for the State ofTexas, have read the Motion for Extension ofTime to File the State's Brief, and swear that the information contained therein is true and correct."

T. PHILIP WASHINGTON Assistant Criminal District Attorney Galveston County, Texas

SWORN TO AND SUBSCRIBED before me onNovember 12, 2015.

, ••"10",,, HEATHER GRUBEN " • ..,.. "".,,_ 1"\**ll~~'r-~:'** NotOIV PubliC. Stote of .1exos !**,,\.~}**.. E MV Commission Expues \:;;,';.:\::;'./ May 06, 2019**'·~IW** .....·

# ~D**n.~** NOTARY PUBLIC in and for the State ofTexas

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