*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 2/9/2015 11:08:05 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-14-00961-cr FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 2/9/2015 11:08:05 AM CHRISTOPHER PRINE CLERK

NO. 14-14-00960-CR & 14-14-00961-CR CALLIE RENEE INMAN, IN THE COURT OF APPEALS

APPELLANT v. FOURTEENTH SUPREME

JUDICIAL DISTRICT THE STATE OF TEXAS,

APPELLEE HOUSTON, TEXAS MOTION FOR EXTENSION OF TIME TO FILE STATE'S RESPONSE BRIEF TO THE HONORABLE COURT OF APPEALS:

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 charged with of intoxicated manslaughter with vehicle and

intoxicated assault with vehicle causing serious bodily injury. The case is styled as

State oj Texas v. Co/lie Rmee II/mOIl, in the 56'111 Judicial District Court of Galveston County, Texas, Cause No. 14-CR-0611 & 14-CR-0612. An Application for Writ of

Habeas Corpus was filed 11/14/2014 and denied 11/25/2014. Appellant filed

timely Notice of Appeal. The Appellant's brief was filed with this Court on January 20, 2015. 2. The present due date for filing the State's brief is February 9, 2015. 3. This is the State's first motion for extension of time to file its brief.

4. The State requests an extension file its brief on or before April 9, 2015.

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

five days, the undersigned attorney for the State:

• Has been working on a rather large and complex State's appeal on

State v. Hector Pma, 14-14-00746-CR It is due on 2/11/2015. • Has been working on a supplemental brief ordered in Javia Sillqlfize JOhllSOl1 v.

State, 01-14-00185-CR, due on 2/12/15. • Assisted in preparing for Oral Arguments on Villcmt Zahorik v. State, 14-13-

00763-CR Oral Arguments were set for 11/17/14 and reset the same day. Arguments were held on 1/12/2015. • Completed the State's response brief on Vallessa Vall-Ness v. State, 01-13-

00607-CR on January 7, 2015. • Completed the State's response brief on Adams OIfZeJ/1IC v. State, 01-14-00242-

CR on December 16, 2014. • Completed the State's response brief on Howard Hams v. State, 14-14-000391-

CR & 14-14-000392-CR on December 3, 2014. • Is solely responsible for all Post-Conviction Writs of Habeas Corpus for

Galveston County and completed 6 post-conviction writ answers on case

numbers: 13-CR-2144-83-1 (Earl Morrhead); 11-CR-3078-83-1 (RolUfy OWCIIS); 11-CR-021O-83-2 (JB Degrassa); 37968-83-2 (Michael Richie); 08-CR-2835-83-1

(Pedro Cabrrra) 11-CR-1177-83-1, 11-CR-1178-83-1, 11-CR-1179-83-1 (Michael Shqyne Hallsley) 03-CR-0733-83-4 (RJ/Ssel/ Kevill Thompsoll). • Was out of state for nearly 2 weeks.

• During the Christmas and New Year's Holidays, caught the flu and was out

sick for several days. 6. The State must also complete its response brief to Bralldoll Derrail EvallS v.

State, 01-14-00345-CR, due on 3/9/2015.

7. The State must also complete its response brief to Fahd Saad Tallash v. Siale,

14-14-00463-CR, due on 3/16/2015. 8. The State must also complete its response brief to Del/llis Roy Reddillg v. Siale,

01-14-00536-CR, due on 2/9/2015. 9. The State must also complete its response brief to Liollel Frallklill v. Siale, 14-

14-00559-CR, due on 2/17 /2015. 10. The State must also complete its response brief ClYde Edwill Hedrick v. Siale,

14-14-00378-CR, due on 4/6/2015. 11. The State must also complete its response brief to Joshlla Dwtrylle Bledsoe v.

Slate, 14-14-00380-CR, due on 3/9/2015.

WHEREFORE, PREMISES CONSIDERED, the State respectfully requests that this Court of Appeals extend the time to file the State's brief until ApriJ9, 2015.

Respectfully submitted, JACK ROADY CRIMINAL DISTRICT ATTORNEY GALVESTON COUNTY, TEXAS lsI Rebecca Klarel/ REBECCA KLAREN 600 59 th Stteet, Suite 1001 Galveston County, Texas 77551 Tel.(409)766-2355, fax (409)766-2290 State Bar Number: 24046225 rebecca.klaren@co.galveston.tx.us

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

and consists of SIS words.

lsI Rebecca Klarev REBECCA KLAREN 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 Jeth Jones, Attorney for Appellant, at

jjones@joneslawfirm.com or 1100 Rosenburg Ave, Galveston, TX 77550, on February 9, 2015.

lsI Rebecca Klare/l REBECCA KLAREN Galveston County, Texas

AFFIDAVIT THE STATE OF TEXAS

COUNTY OF GALVESTON

Before me, the undersigned authority, on February 9, 2015, appeared Rebecca Klaren, who by me duly sworn did depose and state on oath the following:

"I, Rebecca Klaren, Attorney for the State of Texas, have read the Motion for Extension of Time File the State's Brief, and swear that the

information contained therein is true and correct."

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Assistant Criminal District Attorney Galveston County, Texas SWORN TO AND SUBSCRIBED before me on February 9, 2015.

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NOTARY PUBLIC in and for the State of Texas e CAlHeRINEN. NELSON t MY COMMISSION EXPIRES ! FebnlaIy 19. 2017 •• •