Mr. Steven Perez

TDCJ-CID #1514617

Connally Unit

f9f? 7R11Q DEC 212016 Kenedy, Texas 78119

December 13, 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.

Thank you.

Respectfully submitted,

^—-*A

itutivtu ii\

OOURTOFCRIMIMAI APPEALS

Steven Perez*=^

FSLED IN

COURT OF CRIMINAL APPEALS

Abel Acosta, Cierk
No.

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 respectfully moves the Court for a 60-day exten

sion of time, or until March 20, 2017, to file his petition for discretionary

review, as authorized by Rules 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 In re1 Steven Perez, No.

13-16-00593-CR and No. 13-16-00594-CR.

2. The style and number 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 denied Mr. Perez's Petition for Writ of

Mandamus on November 2, 2016.

5. The court of appeals denied Mr. Perez's timely filed Motion for

Rehearing on December 5, 2016.

6. The present deadline for filing a petition for discretionary review

under Rule 68.2(a) of the Texas Rules of Appellate Procedure is;January 4,

2017.

7. The present deadline for filing a motion for extension of time to

file a petition for discretionary review under Rule 68.2(c) of the Texas

§ IN THE COURT OF

8

§ CRIMINAL APPEALS

§ OF TEXAS
Rules of Appellate Procedure is January 19, 2017.

8. The length of time requested is 60 days from the present deadline

for filing a motion 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 in question 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 has very 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 be prejudicial 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 of Appellate Procedure.
SUBSCRIBED and SUBMITTED by placing in prison mailbox on this the _/J_

day of December, 2016.

Respectfully submitted,

STEVEN PEREZ,'Pro Se

TDCJ-CID #1514617

Connally Unit

899 FM 632

Kenedy, Texas 78119

DECLARATION

"I, STEVEN PEREZ, TDCJ-CID #1514617, presently incarcerated

at the Connally Unit in the Texas Department of Criminal Justice

Correctional Institutions Division in Karnes County, Texas, declare

under penalty of perjury under Chapter 132 of the Texas Civil Prac

tice and Remedies Code, that the foregoing statements are true and

correct and that I placed this Motion in the prison mailbox on this

the yt, day of December, 2016.

"EXECUTED on this the J3_ day of December, 2016."

STEVEN PEREZ

CERTIFICATE OF SERVICE

I certify that a true and correct copy of this Motion has been served on

opposing counsel on this the Jj|_ day of December, 2016, by U.S. mail through

the prison mailbox, 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