PD-0462-15
NO. SIOZES&IV
SHAWN MAYREIS/ § in TlJE^5i!M3V(&Bi/yiiJo jo lanoo
TDCJ-CID #1876310, § Ml Q3AI3D3H
§
Appellant/Petitioner/ §
§ CRIMINAL APPEALS
VS. §
§
THE STATE OF TEXAS, § FILED IN
Appellee/Respondent.
§
§ OF TEXAS
COURT OF CRIMINAL APPEALS
APR 24 2015
APPELLANT'S MOTION FOR EXTENSION OF TIME TO
FILE PETITION FOR DISCRETIONARY REVIEW
Abel Acosta, Clerk
TO THE HONORABLE COURT OF CRIMINAL APPEALS:
Appellant Shawn Mayreis respectfully moves the Court for a 60-day exten
sion of time/ or until July 7, 2015, to file his Petition for Discretionary
Review (PDR), as authorized by Tex.R.App.P. 10.5(b) and 68.2(c).
1. This case is presently pending in the Fourteenth Court of Appeals/
Houston/ Texas.*
2. The style and number of the case is Shawn Mayreis v. The State of
Texas, Appeal No. 14-13-00769-CR.
3. The style and number of the case in the trial court is The State of
Texas v. Shawn Mayreis, Cause No. 1340556; from the 184th District Court of
Harris County/ Texas.
4. The date of the Court of Appeals' judgment is March 24, 2015.
5. The Houston Court of Appeals affirmed the conviction on March 24,
2015.
6. The present deadline for filing a PDR is April 23, 2015. The
present deadline for filing a motion for extension of time to file a PDR under
Tex.R.App.P. 68.2(c) is May 8, 2015.
* The Court of Appeals previously granted Mr. Mayreis an extension of time to file a motion
for rehearing. That deadline is May 8, 2015. But after careful consideration, Mr. Mayreis has
decided not to file a motion for rehearing with the Court of Appeals.
Appellant's Motion for Extension of Tine to File Petition for Discretionary Review - Page 1
Mr. Shawn Mayreis
TDCJ-CID #1876310
Connally Unit
899 FM 632
Kenedy, Texas 78119
Texas Court of Criminal Appeals
Court Clerk
P.O. Box 12308
Capitol Station
Austin, Texas 78711
Re: Shawn Mayreis v. The State of Texas, COA No. 14-13-00769-CR, TC No.
1340556
Dear Court Clerk:
Please file the enclosed Pro Se Appellant's Motion for Extension of Time to
File Petition for Discretionary Review. Please notify me of any action taken
by the Court on my case.
Thank you.
Respectfully submitted,
Shawn Mayreis, Pro Se
Date
n 4p^ *5"~
7. The length of time requested for the extension is 60 days from the
present deadline for filing a motion for extension of time to file a PDR under
Tex.R.App.P. 68.2(c).
8. The number of extensions previously granted regarding the item in
question is none.
9. The facts relied upon to show good cause for the requested extension
are:
a. Mr. Mayreis was represented by court-appointed counsel during
the appeal of this conviction to the Court of Appeals.
b. The trial court has not appointed counsel to file a PDR.
c. The legal and factual issues addressed by the Court of Appeals
are complex, and Mr. Mayreis cannot adequately prepare his PDR
before the present deadline.
d. Mr. Mayreis has no access to a copy machine and will have to mail
the PDR home when complete to obtain copies for filing and service of
process.
e. Mr. Mayreis needs additional time to either prepare and file the
PDR pro se or to seek legal assistance for filing the PDR.
10. Mr. Mayreis has neither the time nor the resources to ask opposing
counsel whether he or she has any objections to this Motion. The granting of
this Motion will not be prejudicial to the State because it will not undo past
executed effects of the judgment.
WHEREFORE/ Appellant Shawn Mayreis respectfully moves the Court for a 60-
day extension of time/ or until July 7, 2015/ to file his Petition for
Discretionary Review/ as authorized by Tex.R.App.P. 10.5(b) and 68.2(c).
SUBMITTED and SUBSCRIBED on this the I^f day of April/ 2015.
Respectfully submitted/
Shawn Mayreis/ Pro Se
TDCJ-CID #1876310
Connally Unit
899 FM 632
Kenedy/ Texas 78119
Appellant's Motion for Extension of Time to File Petition for Discretionary Review - Page 2
DECLARATION
"1/ Shawn Mayreis/ TDCJ-CID #1876310/ presently incarcerated in
the Texas Department of Criminal Justice Correctional Institutions
Division at the Connally Unit in Karnes County/ Texas/declare under
penalty of perjury under Chapter 132 of the Texas Civil Practice and
Remedies Code and 28 U.S.C. § 1746/ that the facts stated in this
Motion for Extension of Time are true and correct and that I placed
this Motion for Extension of Time in the prison mailbox on this date.
"Executed on this the ,_Q_ day of April/ 2015."
Shawn Mayreis
CERTIFICATE OF SERVICE
I certify that on this the I I day of April/ 2015, I served the following
parties: with a true and correct copy of this Motion for Extension of Time by
U.S. mail through the prison mailbox in a postpaid package to the addresses
written below:
Harris County District Attorney's Office
Appellate Division
1201 Franklin
Houston, Texas 77002
State Prosecuting Attorney
P.O. Box 13046
Capitol Station
Austin, Texas 78711
Shawn Mayreis
•Pfpellant's Motion for Extension of Tine to File Petition for Discreticnary Review - Page 3