ACCEPTED 14-17-00241-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 12/22/2017 10:28 AM CHRISTOPHER PRINE CLERK

NOs. 14-17-00240-CR, 14-17-00241-CR, 14-17-00242-CR

KALEB JAKOBI JAMAL THOMAS, IN T HE COURT OF APPEALS FILED IN 14th COURT OF APPEALS APPELLANT HOUSTON, TEXAS 12/22/2017 10:28:19 AM v. FOURTEENTH SUPREME CHRISTOPHER A. PRINE JUDICIAL DISTRICT Clerk

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 D istrict Attorney of G alveston 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. T he appellant was convicted on 3 cases of Aggravated Robbery and was sentenced o n 2/ 27 / 2017. T he trial case is styled as State of Texas v. Koleb Jakobi Jamal Thomas, in the 56 th J udicial D istrict Court of Galveston County, Texas, Cause Nos. 15-CR- 0454, 15-CR-0455, 15-CR-0456. Appellant filed timely Notice o f Appeal. The Appellant's brief was filed with this Court on 8/ 14/ 17.

2. T he present due date for filing the State's brief is 12/ 22 / 2017 .

3. T his is the State's third motion fo r extension of time to file its brief.

4. The State requests an extension to file its brief on or befo re 12/ 29 / 2017.

5. T he State requests this extension not for delay but because during the last sixty days, the undersigned attorney fo r the State:

1 • Represented the State at Oral Arguments in Aarol/ Shawn Lil/dsey v. State, 14-16- 00S95-CR on 12/ 19/2017.

• Completed a response brief in Craig Sal/ders v. State, 01-17-0011 3-CR, filed on 12/6/2017.

• Completed a response brief in Aaroll ShawlI Lindsey v. State, 14-16-00S95-CR, filed on November 20, 2017. T he State has O ral Arguments set for December 19, 2017.

• Completed a response brief in Charles Martin v. State, 14-17-00346-CR, filed on ovember 20, 2017.

• Completed a response brief in Deshoatlll Gmll v. State, 14-16-00669-CR & 14-16- 00670-CR, filed on ovember 7,2017.

• Completed a response brief in j eml'fY jennaille Sanford v. State, 14-16-0090S-CR, filed on October 11 , 2017.

• Completed a response brief in Grandisol/ Kim Rogerson v. State, 14-16-00926-CR & 14-16-00927 -CR, filed on October 5, 2017.

• Assisted in preparing fo r O ral Arguments on A ntonio Thomas Elizondo v. State, 14- 16-00S71-CR, 14-16-00S72-CR, 14-16-00S73-CR, heard on October 24,2017.

• T he undersigned State's attorney was out of the state from November 12th through November 14th.

• T he undersigned State's attorney was out o f the state fro m December 12th through December 14th.

WHEREFORE, PREIvIISES CONSIDERED, the State respectfully requests that this Court o f Appeals extend the rime to file the State's brief until D ecember 29, 2017. Respectfully submitted,

JACK ROADY CRIIvII AL DISTRICT ATTORNEY

2 GALVESTON COUNlY, T EXAS

lsi Rebecca Klann REBECCA KLAREN Assistant Criminal District Auorney 600 59 th Street, Suite 1001 Galveston County, Texas 77551 Tel. (409)766-2355, fax (409)766-2290 State Bar N umber: 24046225 rebecca.klarcntak o.galves ton. tx. us

CERTIFICATE OF COMPLIANCE

The undersigned Auorney for the State certifies this brief is computer generated, and consists of 364 words. lsi Rebecca Klaren REBECCA KLAREN Assistant Criminal District Auorney Galves ton County, Texas

CERTIFICATE OF SERVICE

T he undersigned auorney for the State certifies that a copy o f the above motion was emailed via eFiling e-service to Winston Cochran, auorney for Appellant, winstoncoc [email protected] on December 22, 2017. lsi Rebecca Klan n REBECCA KLAREN Assistant Criminal D istrict Auorney Galveston County, T exas

3 AFFIDAVIT

THE STATE OF TEXAS

COUNTY OF GALVESTON

Before me, the undersigned authority, on December 22, 2017, 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 to File the State's Brief, and swear that the

information contained therein is true and correct."

~ REBECCA KLAlillN Assistant Criminal District Attorney Galveston County, Texas

SWORN TO AND SUBSCRIBED before me on December 22, 2017.

r =/.~;.~:.~ .,~HEA~IHER~GRUB~EN~ UP- Cttl4M e; ~ ,~Itl ~..~.,:'i NOIOIV Public. Slote of le,as My CommIssIon Expires O"fARY PUBLIC I ' n and cor L~ ";~.:r.:::~~.. May 06. 2019 the State of Texas

4