Mr. Steven Perez TDCJ-CID #1514617 Connally Unit 

# f9f? 7R11Q DEC212016 Kenedy, Texas 78119 

## December13, 2016 AbelAcosta,Clerk Texas Court of Criminal Appeals Court Clerk, Abel Acosta P.O. Box 12308 Capitol Station Austin, Texas 78711
Re: In re Steven Perez 

### Court of Appeals No. 13-16-00593-CR and 13-16-00594-CR
Dear Court Clerk: Please file the enclosed Motion for Extension of Time to File Petition for Discretionary Review. Thankyou. Respectfully submitted, 

## ^—-*A itutivtuii\ 

### OOURTOFCRIMIMAIAPPEALS

*=^ Steven Perez



### FSLEDIN 

### COURTOFCRIMINALAPPEALS

AbelAcosta,CierkNo.
IN RE STEVEN PEREZ TDCJ-CID #1514617 RELATOR'S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE COURT OF CRIMINAL APPEALS: 

### Relator STEVEN PEREZ respectfullymoves the Court for a 60-day exten 

### sion of time, or until March20, 2017, to file his petition for discretionary 

### review, as authorizedbyRules 68.2(c) and 10.5(b) of the Texas Rules of Appellate Procedure. 

### 1. The style and numbers of this original proceeding in the Corpus Christi Thirteenth District Court of Appeals are Inre1 Steven Perez, No. 13-16-00593-CR and No. 13-16-00594-CR. 

### 2. The style andnumber of the case in the trial court are State of Texas v. Steven Perez, No. 07-CR-0159-B; from the 117th District Court of Nueces County, Texas. 

### 3. The date of the court of appeals' judgment is November 2, 2016. 

### 4. The court of appeals deniedMr. Perez's Petition for Writ of Mandamus onNovember 2, 2016. 

### 5. The court of appeals deniedMr. Perez's timely filedMotion for Rehearing onDecember 5, 2016. 

### 6. The present deadline for filing apetition for discretionary review under Rule 68.2(a) of the Texas Rules ofAppellate Procedure is;January 4, 2017.7. The present deadline for filing amotion for extension of time to 

### file apetition for discretionary reviewunder Rule 68.2(c) of the Texas § IN THE COURT OF 8 § CRIMINAL APPEALS § OF TEXASRules of Appellate Procedure is January 19, 2017. 8. The length of time requested is 60 days from the present deadline for filing amotion for extension of time to file a petition for discretion 

### ary review under Rule 68.2(c) of the Texas Rules of Appellate Procedure. 9. The number of extensions of time previously granted regarding the item inquestion is none. 10. The facts relied upon to show good cause for the requested exten sion are below: (a) the petition involves complex legal and factual issues that cannot be adequately prepared before the present deadline because Mr. Perez hasvery limited access to the law library and the pertinent research software. 11. Mr. Perez has neither the time nor the resources to ask opposing counsel whether the State has any objections to this Motion. Nevertheless, the granting of this Motion will not beprejudicial to the State because the granting of this Motion will not undo past executed effects of the judgment and the State is not required to file a response to a petition for discre tionary review. 12. This Motion is not filed to delay these proceedings but in good faith and so that justice may be served. 13. Mr. Perez filed this Motion as soon as he became aware of the need to file it. WHEREFORE, Relator STEVEN PEREZ respectfully moves the Court for a 60- 

### day extension of time, or until March 20, 2017, to file his petition for discretionary review, as authorized by Rule 68.2(c) and 10.5(b) of the Texas Rules ofAppellate Procedure.

### SUBSCRIBED and SUBMITTEDbyplacing inprisonmailbox on this the_/J_ day ofDecember, 2016. Respectfully submitted,
STEVENPEREZ,'Pro Se TDCJ-CID #1514617 Connally Unit 899 FM 632 Kenedy, Texas 78119
DECLARATION 

### "I, STEVENPEREZ, TDCJ-CID #1514617, presently incarcerated at the ConnallyUnit in the Texas Department of Criminal Justice Correctional Institutions Division inKarnes County, Texas, declare 

### underpenalty of perjuryunder Chapter 132 of the Texas Civil Prac tice and Remedies Code, that the foregoing statements are true and 

### correct and that Iplaced this Motion in the prisonmailbox on this 

### the yt, day of December, 2016. 

### "EXECUTEDon this theJ3_dayof December, 2016."

STEVEN PEREZ CERTIFICATE OF SERVICE 

### Icertify that atrue andcorrect copy of this Motionhas been servedon 

### opposing counsel on this theJj|_day of December, 2016, byU.S. mail through the prisonmailbox, addressed as follows:
James Ode11 Assistant District Attorney Nueces County Courthouse 105th Judicial District of Texas 901 Leopard St. Room 206 Corpus Christi, Texas 78401

STEVEN PEREZ