Ferralez, Samuel Arrenado

Opinion

PD-0590-15

APPEAL NO. 13-12-00651-CR RECEIVED SN COURT OF CRIMINAL APPEALS- IN THE MAY 15 2015 371ST COURT OF APPEALS

AT TARRANT , TEXAS Abel Acosta, Clerk

SAMUEL ARRENADO FERRALEZ FILED IN Appellant COURT OF CRIMINAL APPEAL? MAY 15 2015 THE STATE OF TEXAS Appellee Abel Acosta, Clerk

APPEAL OF CAUSE NUMBER C-371-010299-1246930 FROM THE

13TH TEXAS COURT OF APPEALS

PETITIONER'S FIRST MOTION FOR EXTENSION OF TIME TO FILE PETITIONER'S PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE JUSTICES OF THE TEXAS CORT OF CRIMINAL APPEALS:

Comes "now SA1VUEL AEKENADO FERRALEZ , Petitioner pro se, and respectfully moves

the Court to extend the deadline for filing his Petition for Discretionary

Review by thirty (30) days. In support, Petitioner would show the following:

I.

On the 14th day of September A.D. 2015- the Jury found

Petitioner guilty of MURDER - The Jury assessed punish

ment at 99 years imprisonment in the Texas Department of Criminal

Justice.

II.

On the 25TH day of MARCH A.D. 2015 , the 13TH Texas Court

of Appeals Affirmed Petitioner's Conviction, and Petitioner filed with the convicting Court his Writ of Habeas Corpus to file a PDR, the Notice of PDR

was GRANTED and the Court gave Petitioner 30 days to file the PDR.

The deadline for filing Petitioner's PDR is on the }^q day of /kyy/ A.D., 2015.

IV.

This is Appellant's first request for extension of time. Petitioner

is unable to meet the deadline for the following reasons:

Petitioner has been transfered from the Unit of Assignment to the James V. Allred Unit. The Texas Department of Criminal Justice has a time limit

in which to send offenders thier propert according to policy up to thirty to 60 days. When the Court GRANTED the Habeas matter for Out-of-time PDR

Petitioner was on the newly assigned Unit without his property, and has just recieved his personal and legal property. Therefore, Petitioner respectfully request that the Court will consider the matters herein and grant Petitioner Motion for an Extension n of Time and set the new deadline for the X0 day of W$fa XaC A.D., 2015. V.

For: the reasons stated above, Petitioner respectfully request an addition

al thirty (30) days to complete the Petition for Discretionary Review. VI.

Petitioner prays that the Court GRANTS this motion and extend the time

Petitioner's pro se PDR by thirty (30) days extending the deadline to 2Q days.

Respectfully submitted,

.qflivriFT. apRFM&m reppar.E7 TmT-Tn M-, -IPTQF.1

Jamas V. Allnpd rtiil- 2101 FM 369 Nbrth Petitioners Motion for Extension of Time, 2. iq^q psr^_l Texas 76367 CERTIFICATE OF SERVICE

I hereby certify that on the 11 day of _ MAY A.D. 2015,

a true and correct copy of Petitioner's Motion for Extension of Time to file a Petition for Discretionary Review has been mailed to the TCCA Clerk of the Texas Court of Crimianl Appeals at P.O. Box 12308, Capitol Station, Austin, Texas 78711 via the United States Postal Service through first class mail. Executed and signed this the 11thday of MAY A.D., 2015.

rTtioner Pro se

TDCJ # 1809763 James V. Allred Unit 2 101 FM 369 North Iowa Park, Texas 76367

VERIFICATION

I1 SAm^e./ recffi \CL > TDCJ # /#0 9?S 5 , being presently incarcerated the James V. Allred Unit of the Texas Department of Criminal Justice - In stitutional Division in Wichita County, Texas, verify and declare under penalty of perjury that the foregoing statements are true and correct.

Executed and signed this the ^ day of ^ A.D. 2015

Petitioner Pro s e TDCJ # 1809763 James V. Allred Unit 2101 FM 369 NDrth Iova Park, Tx 76367

Petitioners Motion for Extension of Time, 3.