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.