Case Information

*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 3/23/2015 3:17:05 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-14-01025-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 3/23/2015 3:17:05 PM CHRISTOPHER PRINE CLERK No. 14-14-01025-CR 14-14-01026-CR 14-14-01027-CR In the Fourteenth Court of Appeals, Houston, Texas CARLOS GALLEGOS-PIEDRA Appellant v.

THE STATE OF TEXAS Appellee Appellant’s Second Motion for Extension of Time to File Brief Respectfully Submitted by:

THE LAW OFFICE OF KYLE VERRET, PLLC

Counsel for Appellant

11200 Broadway, Suite 2743

Pearland, Texas 77584

Phone: 281-764-7071

Fax: 281-764-7071 Submitted:

Email: kyle@verretlaw.com March 23, 2015

*2 No. 14-14-01025-CR 14-14-01026-CR 14-14-01027-CR In the Fourteenth Court of Appeals, Houston, Texas CARLOS GALLEGOS-PIEDRA 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: March 23, 2015

Length of Extension Sought: Thirty (30) days (to April 22, 2015)

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 last motion to extend time to file brief, Appellant has completed and filed an appellant brief in appeal number

01-14-00895-CR, which is presently due to be filed with the First Court of

Appeals on March 13, 2015.

The record in these causes is over 400 pages. Counsel needs additional time to review the record and prepare a cogent and succinct brief.

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

April 22, 2015. Appellant prays all other relief to which he may be entitled.

Respectfully submitted,

/s/ Joseph Kyle Verret

THE LAW OFFICE OF KYLE VERRET, PLLC

Counsel for Appellant

11200 Broadway, Suite 2743

Pearland, Texas 77584

Phone: 281-764-7071

Fax: 281-764-7071

Email: kyle@verretlaw.com

Certificate of Service I certify that a true and correct copy of the foregoing Appellant's Second Motion for Extension of Time to File Brief was served on this 23rd

day of March, 2015, on the Counsel for the Appellee, David Bosserman, at

the Brazoria County Criminal District Attorney’s Office by e-service

through electronic filing.

/s/ Joseph Kyle Verret