ACCEPTED
06-15-00194-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
12/24/2015 11:39:44 AM
DEBBIE AUTREY
CLERK
SIXTH COURT OF APPEALS
FILED IN
06-15-00194-CR 6th COURT OF APPEALS
TEXARKANA, TEXAS
12/28/2015 9:07:00 AM
Natalie Ausbie Reynolds, Appellant DEBBIE AUTREY
Clerk
v.
State of Texas, Appellee
On Appeal from the 354th District Court
Hunt County
Cause No. 29263
Motion to Extend Time to File
Appellant’s Brief
Michael Mowla
P.O. Box 868
Cedar Hill, TX 75106
Phone: 972-795-2401
Fax: 972-692-6636
michael@mowlalaw.com
Texas Bar No. 24048680
Attorney for Appellant
To the Honorable Justices of the Court of Appeals:
Appellant Natalie Ausbie Reynolds moves for an extension of time of 30
days to file the Appellant’s Brief [See Tex. Rule App. Proc. 10.5(b) and 38.6(c)]:
1. This case is on appeal from the 354th District Court of Hunt County.
2. The case below is styled State v. Reynolds, and is numbered 29263.
3. Sentence was imposed in open court on October 20, 2015.
4. Appellant was convicted of Official Oppression.
5. The clerk’s record was filed on December 23, 2015.
6. The reporter’s record was filed on December 22, 2015.
7. The Appellant’s Brief is due on January 22, 2016.
8. Appellant requests an extension until February 22, 2016 to file the
Appellant’s Brief.
9. No previous extension to file the Appellant’s Brief has been filed.
10. Appellant relies on the following facts as good cause for the requested
extension: undersigned attorney for Appellant is presently working on two
applications for writs of habeas corpus due to be filed by the middle of January
2016. One deals with a continuation of the underlying issues in Miller v. Alabama,
132 S.Ct. 2455 (2012). The other deals with the sex offender registration statute.
11. Further, attorney for Appellant has the following briefs, petitions for
discretionary review, or other pleadings due soon:
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Appellant’s Brief in Nguyen v. State, 06-15-00127-CR, due on
January 4, 2016 in the Sixth Court of Appeals.
Petition for Discretionary Review in Lowe v. State, PD-1427-15, due
on January 4, 2016 in the Court of Criminal Appeals.
Appellant’s Brief in USA v. Ziba, 15-10873, due on January 15, 2016
in the Fifth Circuit.
Appellant’s Brief in Jack v. State, 01-15-00848-CR, due on January
18, 2016 in the First Court of Appeals.
Appellant’s Brief in Perez v. State, 07-15-00320-CR, due on February
16, 2016 in the First Court of Appeals.
12. In addition, attorney for Appellant has been working on two complex
death penalty habeas cases - Ex parte Thomas, F86-85539, in the 194th Judicial
District Court, and Green v. Director, 3:15-cv-02197-M-BH, in the Northern
District of Texas.
13. Also on January 13, 2016, attorney for Appellant has oral argument
before the Court of Criminal Appeals in Shortt v. State, PD-0597-15.
14. Finally, during the week of January 25, 2016, attorney for Appellant
has a jury trial in a murder case in State v. Robic, F15-23573, in the 282nd District
Court.
15. These cases are in addition to the hearings and trial dockets of
attorney for Appellant.
16. Attorney for Appellant has a responsibility to Appellant to provide
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effective assistance of appellate counsel, see Evitts v. Lucey, 469 U.S. 387, 392
(1985), and attorney for Appellant believes that that the requested additional time
is necessary to provide such counsel.
17. This Motion is not filed for purposes of delay, but so that justice may
be served.
Prayer
Appellant prays that this Motion for Extension of Time to File Appellant’s
Brief be granted.
Respectfully submitted,
Michael Mowla
P.O. Box 868
Cedar Hill, TX 75106
Phone: 972-795-2401
Fax: 972-692-6636
michael@mowlalaw.com
Texas Bar No. 24048680
Attorney for Appellant
/s/ Michael Mowla
Michael Mowla
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Certificate of Service
I certify that on December 24, 2015, a true and correct copy of this
document was served on Hunt County District Attorney Nobie Walker, 2507 Lee
Street, Greenville, TX 75401, phone 903-408-4180, fax 903-408-4296,
nwalker@huntcounty.net, by email.
/s/ Michael Mowla
Michael Mowla
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