NO.Ol-14-00954-CR 

RALPH GARCIA, JR., 

APPEllANT 

IN THE COURT OF APPEALS 

v. 

THE STATE OF TEXAS, 

APPELLEE 

FIRST SUPREME 

DISTRICT 

HOUSTON, TEXAS 

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 MURDER, and was sentenced on 10/22/2014. 

The trial case was styled as State of Texas v. Rolph Garcia, Jr., in the 405th Judicial 

District Court of Galveston County, Texas, Cause No. 12-CR-2430. Appellant 

filed timely Notice of Appeal. The Appellant's brief was filed with this Court on 

6/24/2015. 

2. The present due date for filing the State's brief is 7/24/2015. 

3. This is the State's first motion for extension of time to file its brief. 

4. The State requests an extension to file its brief on or before 9/24/2015. 

5. The State requests this extension not for delay but because during the last seventy1 

ACCEPTED

01-14-00954-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS

7/24/2015 10:12:34 AM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 7/24/2015 10:12:34 AM CHRISTOPHER A. PRINE Clerk
five days, the undersigned attorney for the State: 

• Completed a State's supplemental brief in JOllathall Leal v. State, 14-13-

00208-CR on May 22, 2015. 

• Attended the 2015 Robert O. Dawson Conference on Criminal 

Appeals CLE in Austin from May 27 to May 29, 2015. 

• Completed a State's response brief in Lzmar H'II/ter v. State, 01-14-

00895-CR, on 7/7/2015. 

• Handled 46 expunctions and nondisclosures, and 

misidentification expunctions. 

• Completed 3 post-conviction writ answers on case numbers: 11-

CR-0345-83-1 (Mario Meza); 00-CR-1444-83-1 (Eldred Rtid); 12-CR3307-83-1 (Thaddms Williams). 

WHEREFORE, PREMISES CONSIDERED, the State respectfully requests 

that this Court of Appeals extend the time to file the State's brief until September 24, 

2015. 

Respectfully submitted, 

JACK ROADY 

CRIMIN DISTRICT ATTORNEY 

GAL TON COUN , TEXAS 

,vJV\j /LINDBLADE 

As' nt Criminal District Attorney 

600 59th Street, Suite 1001 

Galveston County, Texas 77551 

Tel.(409)766-2355, fax (409)766-2290 

State Bar Number: 24062850 

allison.lindblade@co.galveston.tx.us 

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CERTIFICATE OF COMPLIANCE 

The undersigned Attorney for the State certifies this brief is computer generated, 

and consists of 260 words. 

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 faxed/ emailed/ eFiled / or mailed to Joseph Salhab, Attorney for Appellant, at 

joscphsalhab@mindspring.com or 2028 Buffalo Terrace, Houston, TX 77019, on July 

24,2015. 

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~~\JN LINDBLADE 

As istant Criminal District Attorney 

Galveston County, Texas 
AFFIDAVIT 

THE STATE OF TEXAS 

COUNTY OF GALVESTON 

Before me, the undersigned authority, on July 24, 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 of Time to File the State's Brief, and swear that 

the infonnation contained therein is true and correct." 

1\ t Criminal District Attorney 

Galveston County, Texas 

SWORN TO AND SUBSCRIBED before me onJuly 24, 2015. 

,II'''''" §~~>J: ~~'. HEATHER GRUBEN i~:,~·t'i NOlarv Public. Stote 01 Texas 

\~.~-'~"/~ MV Commission Expires 

"':':,;*~;:'$:-~ May 06, 2019 NOTARY PUBLIC in and for 

the State of Texas 

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