No. 01

- 15

- 00303

- CR
In the First Court of Appeals, Houston, Texas

CALVIN MCCOLLUM AKA GARY WYMORE Appellant

v. THE STATE OF TEXAS Appellee

Appellant’s Second Motion for
Extension of Time to File Brief

Respectfully Submitted by: Joseph Kyle Verret THE LAW OFFICE OF KYLE VERRET, PLLC Counsel for Appellant TBN: 240429432 11200 Broadway, Suite 2743 Pearland, Texas 77584 Phone: 281

- 764

- 7071 Fax: 281

- 764

- 7071 Submitted: Email: kyle@verretlaw.com August 3 , 2015 ACCEPTED 01-15-00303-CR FIRST COURT OF APPEALS

HOUSTON, TEXAS 8/3/2015 2:07:37 PM CHRISTOPHER PRINE

CLERKNo. 01

- 15

- 00303

- CR
In the First Court of Appeals, Houston, Texas
CALVIN MCCOLLUM AKA GARY WYMORE Appellant

v. THE STATE OF TEXAS Appellee Appellant’s Second Motion for
Extension of Time to File Brief Comes now, Appellant, by and through his undersigned counsel, in the above styled cause and moves this Honorable Court to extend the time for the filing of Appellant's Brief. Per Texas Rule of Appellate Procedure 10.5(b), Appellant provides the following: Current Deadline for Filing: August 3 , 2015 Length of Extension Sought: Thirty (30) Days
Number of Previous Extensions Granted: One

. Basis for Extensions: Appellant's counsel is a solo practitioner with a busy criminal and juvenile defense caseload, which requires regular appearanc es in court on the part of counsel. In the thirty days since the filing of the reporter’s record in this matter ,Appellant coun sel has prepared for trial on an Assault Family Violence case , in the case of The State of Texas v. Warren Jennings in the Cause number of
15

- CR

- 0370 in the 212 th Judicial District Court in Galveston County, Texas
set for trial on the 13 th day of July, 2015

. Additionally, in the thirty days since the filling of the Appellant’s First
Motion for Time of Extension to Fil e Brief , Counsel has prepared for an evidentiary hearing on a Motion for New Trial on a Possession of a
Controlled Substance with Intent to Deliver case , in the case of The State of Texas v, Jose Pablo Hernandez in Cause number 73 970 , in the 239 th Judicial
District Court of Brazoria County , Texas that was held on the 30 th day of July, 2015

. Additionally, in the thirty days since filing of the Appellant’s First Motion for Time of Extension to File Brief, Counsel has prepared for trial in
an Assault of a Public Servant case , in the case of The Sate of Texas v. Laquanda Matthews in the cause 13

- CR

- 2885 in the 10 th Judicial District Court of Galveston County , Texas set for trial on the 3 rd day of August,
2015. Additionally, in the thirty days since filing o f the Appellant’s First Motion for Time of Extension to File Brief, Counsel has prepared for trial in an Aggravated Robbery case, in the case of The State of Texas v. DerrickHolmes in the cause 14

- CR

- 3002 in the 122 nd Judicial District Court of
Galveston County, Texas set for trial on the 3 rd day of August, 2015. All facts recited in this motion are within the personal knowledge of the counsel signing this motion, therefore no verification is necessary under Rule of Appellate Procedure 10.2.
PRAYER FOR RELIEF For the reasons set forth above, Appellant requests that this Court grant this Appellant’s First Motion to Extend Time to File Appellant’s Brief and extend the Deadline for Filing the Appellant’s Brie f up to and including September 2 , 2015. Appella nt prays all other relief to which he may be
entitled.

Respectfully submitted, /s/ Joseph Kyle Verret Joseph Kyle Verret THE LAW OFFICE OF KYLE VERRET, PLLC Counsel for Appellant TBN: 240429432 11200 Broadway, Suite 2743 Pearland, Texas 77584 Phone / Fax: 281

- 764

- 7071 Email: kyle@verretlaw.com

Certificate of Service I certify that a true and correct copy of the foregoing Appellant's FirstMotion for Extension of Time to File Brief was served on this 3r d day of August, 2015 on the Counsel for the Appellee, Rebecca Klaren , at the
Galveston County Criminal District Attorney’s Office by e

- service through electronic filing.

/s/ Joseph Kyle Verret Joseph Kyle Verret TBN: 2402932