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

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 8/3/2015 2:07:37 PM CHRISTOPHER A. PRINE Clerk
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

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 appearances in court on 

the part of counsel.

In the thirty days since the filing of the reporter’s record in this matter, 
Appellant counsel 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 212th Judicial District Court in Galveston County, Texas

set for trial on the 13th day of July, 2015.

Additionally, in the thirty days since the filling of the Appellant’s First 

Motion for Time of Extension to File 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 73970, in the 239th Judicial

District Court of Brazoria County, Texas that was held on the 30th 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 10th Judicial District 

Court of Galveston County, Texas set for trial on the 3rd day of August, 

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 Aggravated Robbery case, in the case of The State of Texas v. Derrick 
Holmes in the cause 14-CR-3002 in the 122nd Judicial District Court of 

Galveston County, Texas set for trial on the 3rd 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 Brief up to and including 

September 2, 2015. Appellant 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 First 
Motion for Extension of Time to File Brief was served on this 3rd 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