IN THE COURT OF CRIMINALAPPEALS OFTEXAS ATAUSTIN, TEXAS
DEW ANMORGAN, § APPELLEE § § v. § NO. PD- § THE STATE OF TEXAS, § APPELLANT §

FROMTHE COURT OF APPEALS FORTHE SECOND DISTRICT OF TEXAS ATFORTWORTH APPEALED FROMCAUSENUMBER02-14-00231-CRAND FROMTHE 21 lTHJUDICIAL DISTRICT COURT OF DENTONCOUNTYIN CAUSE NUMBERF-2013-1704-C, THE HONORABLE L. DEE SHIPMAN, JUDGE PRESIDING

THE STATE'S MOTION TO EXTEND THE TIME FORFILING THE STATE'SPETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLEJUDGES OF SAID COURT: The State, by and through the Criminal District Attorney of Denton County, Texas, respectfully requests that the time for the filing of the State's Petition for Discretionary Review in the above styled and numbered cause be extended pursuant to Texas Rules ofAppellate Procedure 68.2(c) and 10.S(b). In support ofthis motion, the State would showthe Courtthe following: I. The Second Court ofAppeals at Fort Worth released its opinion andjudgment in this case on May 28, 2015. No motions for rehearing or reconsideration have been filed

. PD-0758-15 COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS Transmitted 6/22/2015 3:44:02 PM Accepted 6/24/2015 10:23:10 AM

ABEL ACOSTA CLERK

### II. The present deadline for the filing of the State's Petition for Discretionary Review is June 26, 2015. The State respectfully requests a 15 day an extension oftime until July 13, 2015. 

### III. This is the State's first request for an extension oftime to file the State's Petition for Discretionary Review. 

### IV. The Appellant would show the Court that a reasonable explanation exists for the requested extension. The.facts on which the Appellant relies to reasonably explain the need for this extension are as follows: The Second Court of Appeals released its opinion, on May 28, 2015. From May 27-29, 2015, the undersigned was out ofthe office at a CLE on Criminal Appeals. Since then the undersigned has prepared two appellate briefs: 

### Lim v. State, 02-14-00365-CR, due June 8, 2015, and 

### Martinez-Benitez v. State, 02-14-00440-CR, a murder case, due June 29, 2015. The undersigned has prepared an Order Designating Issues for a habeas writ on F-2013-0120-A(whcl) regarding 

### Ex Parte Derrek Parry. The undersigned has also assisted prosecutors in the trial division prepare for a suppression hearing. Additionally, the undersigned is scheduled to be out of the office on a pre-planned vacation on July 1-2, 2015, and the Denton County District Attorney's Office will be closed in celebration ofIndependence Day on July 3, 2015. The motion is not for delay, but sought in the interest of justice.

2Accordingly, the State respectfully requests that the time for the filing of the State'sPetition for Discretionary Review be extendedto July 13, 2015.
Respectfully submitted,

Assistant Criminal Dis netAttorney Appellate Division State BarNo. 24077065 Denton County, Texas 1450 East McKinney Denton, Texas 76209 (940) 349-2600 yael.zbolon@dentoncounty.com ATTORNEYFORAPPELLANT, THE STATE OF TEXAS

CERTIFICATE OF SERVICE
I hereby certify that a true copy ofthe foregoing motion has been served on the J. Stanley Goodwin, 303 North Carroll, Suite 200, Denton, Texas 76201; and Lisa C

. McMinn, Post Office Box 13046, Capital Station, Austin, Texas 78711-3046, by depositing same in the United States Mail, Postage Prepaid, on this, the 22nd day of June, 2015.

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