NO.Ol-14-00700-CR 

THERRELL DEWAYNE FELDER, IN THE COURT OF APPEALS 

APPELLANT 

v. 

THE STATE OF TEXAS, 

APPELLEE 

FIRST SUPREME 

DISTRICT 

HOUSTON, TEXAS 

UNOPPOSED MOTION FOR EXTENSION 

OF TIME TO FILE STATE'S RESPONSE BRIEF 

TO THE HONORABLE COURT OF APPEALS: 

JUDICIAL 

Now comes Jack Roady, Criminal District Attorney of Galveston 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 of Appeals as follows: 

1. The appellant was convicted of FORGERY, and was sentenced on 7/18/2014. 

The trial case was styled as Siale of Texas v. Themli Dewayne Felder, in the 122nd 

Judicial District Court of Galveston County, Texas, Cause No. 14-CR-0283. 

Appellant filed timely Notice of Appeal. The Appellant's brief was 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 of time to file its brief. 

4. The State requests an extension to file its brief on or 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: 

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ACCEPTED

01-14-00700-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS

11/12/2015 8:20:58 AM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 11/12/2015 8:20:58 AM CHRISTOPHER A. 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 of a Controlled Substance with Intent to Deliver 

Heroin. He was found guilty on November 10, 2015. The 

punishment phase of the trial is to begin this morning. 

WHEREFORE, PREMISES CONSIDERED, the State respectfully requests 

that this Court of Appeals extend the time to file the State's brief until November 30, 

2015. 

Respectfully submitted, 

JACK ROADY 

CRIMINAL DISTRICT A TIORNEY 

GALVESTON COUNTY, TEXAS 

lsI T. PhiliP Washington 

T. PHll..1P WASHINGTON 

Assistant Criminal District Attorney 

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 brief is computer generated, 

and consists of 250 words. 

lsI T. Philip Washington 

T. PHILIP WASHINGTON 

Assistant Criminal District Attorney 

Galveston County, Texas 

CERTIFICATE OF SERVICE 

The undersigned attorney for the State certifies that a copy of the above motion 

was emailed/eFiledtoZachMaloney.AttorneyforAppellant.at 

zachmaloney@gmail.com on November 12, 2015. 

lsI T. Philip Washingtoll 

T. PHILIP WASHINGTON 

Assistant Criminal District Attorney 

Galveston County, Texas 

CERTIFICATE OF CONFERENCE 

The office of the 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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lsI T. Philip Washington 

T. PHILIP WASHINGTON 

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 of Texas, have read 

the Motion for Extension of Time 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 on November 12, 2015. 

, •• "10",,, HEATHER GRUBEN " • ..,.. "".,,_ 1"\ 

ll~~'r-~:' NotOIV PubliC. Stote of .1exos 

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\:;;,';.:\::;'./ May 06, 2019 '·~IW ..... · 

~Dn.~ NOTARY PUBLIC in and for 

the State of Texas 

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