### NO.Ol-15-00220-CR GARYJAMES COX, APPELLANT INTHE COURT OFAPPEALS 

# v. THE STATE OF TEXAS, APPELLEE FIRST SUPREME DISTRICT HOUSTON, TEXAS MOTION FOREXTENSION OFTIME TO FILE STATE'S RESPONSE BRIEF TO THE HONORABLE COURT OFAPPEALS: JUDICIAL

Now comes Jack 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 ENHANCEMENT, and was sentenced on 2/4/2015. The trial case was styled as State 

## ofTexas v. Gary James Cox, in the 12200 Judicial District Court of Galveston County, Texas, Cause No. 13-CR-0183. 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 9/8/2015. 3. This is the State's first motion for extension oftime to file its brief. 4. The State requests an extension to file its briefon orbefore 11/8/2015. 5. The State requests this extension not for delay but because during the last seventyfive days, the undersigned attorney for the State: 1 ACCEPTED 01-15-00220-CR FIRST COURT OF APPEALS

HOUSTON, TEXAS 9/8/2015 10:00:36 AM CHRISTOPHER PRINE

CLERK• Completed a State's response brief in 

### lJunar Hunter v. 

### State, 01-14- 00895-CR, on7/7/2015.
• Completed a State's response brief on Writ of Mandamus in 

### In Re Antonio Sepeda, 14-15-00288-CV, on 8/13/2015.
• Attended a CLE on 7/9/2015.
• Attended a TDCAA Legislative update on 8/20/2015.
• Handled 72 expunctions and nondisclosures, and misidentification expunctions.
• Completed 2 post-conviction writ answers on case numbers: 11- CR-0345-83-1 

### (Mario Meza); 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 Sf. Aubin). 6. The State 

### will also file its motion for rehearing and motion for reconsideration en banc in 

### Villcmt Zahorik v. State, 14-13-00763-CR, due on September 9, 2015. 7. The State must also complete its response briefto

### AllthOl!} Brac!fordv. State, 14- 15-00201-CR & 14-15-00202-CR, due on September 21, 2015. 8. The State must also complete its response briefin 

### Ralph Garcia v. State, 01-14- 00954-CR due on September 24, 2015. 9. The State must also complete its response briefto 

### RobertRollins v. State, 01-14- 00768-CR, due on October26,2015. WHEREFORE, PREMISES CONSIDERED, the State respectfully requests that this Court of Appeals extend the time to file the State's brief until November 8, 2015. Respectfully submitted, JACK ROADY CRIMINAL DISTRICT ATTORNEY 2. STON COUNTY,TEXAS

As . t Criminal DistrictAttorney 

# o59th Street, Suite 1001 Galveston County, Texas 77551 TeL(409)766-2355, fax (409)766-2290 State Bar Number: 24062850 allison.lindblade@co.gaIveston.rx.us 

### CERTIFICATE OF COMPLIANCE The undersigned Attorney for the Stat certifies this briefis computer generated, and consists of352 words. INDBLADE Assi t Criminal DistrictAttorney Galveston County, Texas 

### CERTIFICATE OF SERVICE The undersigned attorney for the State certifies that a copy ofthe above motion
was faxed/ emailed/ eFiled / or mailed to Joel B ett, Attorney for Appellant, at joel@searsandbennetr.com or 1100 Nasa Park ·re 302, Houston, TX 77058, on September 8, 2015.

3 ssistant Criminal District Attorney Galveston County, Texas

### AFFIDAVIT THE STATE OFTEXAS COUNTY OF GALVESTON Before me, the undersigned authority, on September 8, 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 ther' is true and correct."



### ''''•." .JE**~~~ riminal**  DistrictAttorney on County, Texas

SWORN TO AND SUBSCRIBED before me on September 8, 2015.**","111",~** HEAlHER GRUBEN**!~!~\** NolOIV PubliC. State of Texas**~:~.~).J** My commission Eltpires \
..

;;......;; ..**~** May 06, 2019**~"·:"W**...·,··

# ~ 6VVL\?tA-- NOTARYPUBLIC in and for the State ofTexas

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