Kaleb Jakobi Thomas v. State
Date Filed2017-12-22
Docket14-17-00241-CR
Cited0 times
StatusPublished
Full Opinion (html_with_citations)
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:
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• 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
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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 hran@comcast.net on December 22, 2017.
lsi Rebecca Klan n
REBECCA KLAREN
Assistant Criminal D istrict Auorney
Galveston County, T exas
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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.
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";~.:r.:::~~.. May 06. 2019 the State of Texas
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