HungLe, Appellant State ofTexas, Appellee Case Number 01-14-01019-CR FILED IN 1ST COURT OF APPEALS HOUSTON, TEXAS NOV 1 0 2015 CHRISTOP4EF\A. PRINE CLERK. OPHERyA. PR 

# Ml
COURT OF APPEALS 

### IstDISTRICT HOUSTON, TEXAS Pro se Motion for Extension ofTime to File Response toAnders Brief To the Honorable Justices ofsaid Court: 

### Appellant's appointed counsel file a briefin the above styled and numbered

causepursuantto Andersv. California, 386 U.S. 738 (1967). 

### Appellant filed a pro se request for access to the clerk's record andreporter's record in preparation for use in preparing his pro se response to counsel's briefand included a motion forextension oftime to respondto counsel'sAnders brief. 

### This Honorable Court granted said extension which is set to expire on November 2,2015. 

### Appellant is in the transit to another Unit in safekeeping area andcurrently confined in the Life Division of the Texas Department of Justice Center in 

### Huntsville Unit, and has suffered yet another epileptic seizure, caused scalp laceration and became hospitalized at Huntsville Memorial Hospital on 9/29/2015 

### and was ordered by Doctor Windham to remove staples within 7 days (please see 

### attached hospital's report) during his period of extension and appeal response filing. As a result, Appellant has become confused, disoriented, and has shown

### loss memory of past and recent events and needs additional time to be fully recovered mentally andphysically and comprehendhis legal processes. 

### Presently, Appellant lacks the capacity to understand, identify and analyze the relevant issues that are ripe for appeal, formulate a good faith argument, and 

### simultaneously draft and file a clearand conciseresponse to counsel'sAndersbrief 

### withinthetimeremainingonthelastextensiontoNovember2nd, 2015. Appellant's Public Defender counsel refused to provide any legal assistance whatsoever during this process. Moreover, Appellant was located to solitary confinement for his safety for the past 50 days where he has forfeited access to 

### persons in general population who were prepared to assist Appellant with the preparation ofhis response. .Appellant needs to be settled in a new unit where he will be permittedto contactfamily member, to access to any authorities, chaplains, any persons in general population who is willing to assist Appellant with the preparation of his response brief. Appellant has a language barrier and always requires assistance from an interpreter with detailed explanation, guidance and understanding all matters. Appellant is currently relying on a family member to monitor his mental condition and communicate with authorities and medical staff, case progress and retain a private counsel or other professional help but needs additional time to 

### procure said assistance because family members live outside ofthe State ofTexas.Due to Appellant's financial hardship to hire a private counsel, non

### accessible permission for any assistance due to past 50 day safety confinement, 

### now in transit to a new unit, recurring seizures, and incompetency mental condition, Appellant now respectfully requests the Court grant him another 

### Appellate Public Defender Bob Wicoffto substitute Public Defendant Crowley's withdrawal and additional sixty (60) days from the granting ofthe motion to retain another Appellate Public Defender or find an outside assistance and allow time for 

### that professional to help Appellant prepare and file a timely pro se response to 

### counsel's brief and a writ of Habeas Corpus as advised by Appellate Public DefenderCrowley. Respectfully submitted, Hung Le, Pro se Appellant 

# <XU^S Unit,TDCJ# nl<16>£Z2q p&/mnMl~, Texas 7 77pr CERTIFICATE OF SERVICE 

## The undersigned hereby certifies that on this the (& day of ]\/o\/&}4ftfzR 2015, a true and correct copy ofthe foregoing Motion for Extension ofTime to 

### File Response to Counsel'sAnders Briefwas served by U.S. mail on the : Harris County DistrictAttorney's Office 1200 Franklin, Suite 600 Houston, Texas 77002

. 

### Pro seAppellant

# Huntsville MEMORIAL HOSPITAL

Patient Visit* information You were seen today for:

Seizure Scalp laceration Phenytoin overdose rdyc -»• w •

Date: 09/29/15 Account No: H00001033625 Unit No: M000202557 Patient: LE,HUNG 1966229 Location: ER Physician: WINDHAM,WILLIAM A

Staff Your caregivers today were: Physician: WINDHAM,WILLIAM A Nurse: TOG Activity Restrictions orAdditionalInstructions STAPLES; OaJTII'fT'WsYS: THE PATTE^T'S PHENYTOIN SMOULD BETAKEN OUT OFTHECELL AND DISPENSED TO HIM AT DOSING TIMES. HE SHOULD BE OBSERVED TAKLN3 THE PHENYTOIN TO MAKE SURE HE HAS TAKEN IT. Follow-up Please contact the following to make an appointment for follow-up care: TDGJ,PRIMARY CARE DOC

. Note: Your heaftn' care plan may require a referral from your primary care provider prior to making an appointment. Discharge Form The exam and treatment which you have received has been on an EMERGENCY BASIS 

### ONLY- It is not ihMweded to substitute or replace complete medical care. It is advised that you follow the recommendations below;

1. If complications arise, call your doctor immediately. If the doctor cannot be reached return to the Emergency Department at oh(^;i 

### 2. Have your prescriptions filled and follow the directions on the label. 3,, The x-ray report by the Emergency Physician is NOT a final report. A•si "vl o D KJ l\)

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