Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 7/2/2015 11:42:19 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00303-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 7/2/2015 11:42:19 AM CHRISTOPHER 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 First 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 July 2, 2015
*2 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 First 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: July 3, 2015
Length of Extension Sought: Thirty (30) Days
Number of Previous Extensions Granted: None.
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, *3 Appellant counsel has prepared for trial on a third-degree felony kidnapping
and second-degree felony robbery case in the Cause number of 14-CR-2251
and Cause number 14-CR-2252 in the 405 th Judicial District Court in
Galveston County, Texas.
Additionally, in the thirty days since the filling of the reporter’s record,
Counsel has prepared for an evidentiary hearing on a Motion for New Trial
on a capital murder case in Cause number 73841, in the 239 th Judicial
District Court of Brazoria County held on the 1 st day of July, 2015.
Also, Counsel was on family vacation for ten days during this 30-day
period.
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
August 3, 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 2nd day of
July, 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