NO.

IN THE

COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS

FILED IN

COURT OF CRIMINAL APPEALS

OCT 08 2015

Abel Acosta, Clerk

ISAAC GONZALEZ,

Petitioner,

V.

THE STATE OF TEXAS

Respondent.

KeCb a COURT OF OR'»'AL£PPais

OCT 08 2015

•^DelAcoma, Qmk

From Appeal No. 13-15-00334-CR

Trial Court Cause No. 12-3-26,449-A

FIRST MOTION FOR EXTENSION OF TIME TO FILE

PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE JUSTICES OF THE COURT OF CRIMINAL APPEALS:

COMES NOW, Isaac Gonzalez, "Petitioner," pro se, and files this motion for

an extension of at least sixty (60) days in which to file a Petition for Discreti

onary Review. In support of this motion, Petitioner shows the Court the following:

I.

The Petitioner was convicted in the 24th District Court of Victoria County,

Texas, in Cause No. 12-3-26,449-A, styled State of Texas vs. Isaac Gonzalez. On

June 12, 2015, Petitioner filed a motion with the trial court, requesting appoint

ment of counsel for habeas corpus, titled DEFENDANT'S MOTION FOR APPOINTMENT OF

COUNSEL FOR HABEAS CORPUS, UNDER TEXAS FAIR DEFENSE ACT, ARTICLE 1.051 V.A.C.C.P.

On June 19, 2015, Petitioner's motion was denied by the trial court, without an

explanation of why. Petitioner timely filed Notice of Appeal, on June 15, 2015,

appealing to the Court of Appeals for the Thirteenth (13th) Judicial District of

Texas. Said Court of Appeals dismissed the appeal for want of jurisdiction on

September 3, 2015.

Mation For Extensicn of Time - Rage 1
II.

The present deadline for filing the Petition for Discretionary Review is

October 3, 2015. Petitioner has not requested any extension of time prior to this

request.

III.

Petitioner's request for an extension of time is based upon the following

facts: Petitioner is a layman of the law and unskilled in the drafting of legal

documents; Petitioner's access to the law library is limited to about ten (10)

hours per week; Petitioner has not had sufficient time to research for the filing

of a Petition for Discretionary Review; Petitioner does not have the funds to hire

an attorney to handle this litigation; and the matter being appealed is somewhat

new, requiring an extensive amount of research to argue.

PRAYER:

WHEREFORE, PREMISES CONSIDERED, Petitioner prays this Honorable Court will

GRANT this motion and extend the deadline for filing Petition for Discretionary

Review to December 2, 2015, or any day thereafter.

Petitioner prays for general relief and any other relief he may be entitled.

I, Isaac Gonzalez, TDCJ No. 1809453, being presently incarcerated at the

French M. Robertson unit of the Texas Department of Criminal Justice in Jones Cou

nty, Texas; do hereby verify and declare under penalty of perjury that the forego

ing is both true and correct, as well as offered in good faith.

[Tex.Civ.Prac.& Rem.Code § 132.001-003 et seq./Title 28 U.S.C.§ 1746]

(A signed/dated copy of this M3EDCN shall have the same validity as its original)

SIGNED AND EXECUTED on this the 29th day of September, 2015.

RESPECTFULLY SUBMITTED,

/*/ xxdaac

Petitioner, Pro^iS^

Isaac Gonzalez # 1809453

French M. Robertson Unit

12071 F.M. 3522

Abilene, Texas 79601

(325) 548-9035

Motion For Extension of Time - Page 2
CERTIFICATE OF SERVICE:

The above signer hereby certifies that a true and correct copy of the foreg

oing FIRST MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

has been forwarded to all parties in this matter, via 1st Class U.S. Mail, Postage

Pre-Paid, deposited in the outgoing prison mailbox on this the 29th day of Septemb

er, 2015; addressed to:

• Abel Acosta, Clerk • Stephen B. Ty}.er, District Attorney

Texas Court of Criminal Appeals Victoria County, Texas

P.O. Box 12308 205 N. Bridge St., Suite 301

Capitol Station Victoria, Texas 77901

Austin, Texas 78711

• State Prosecuting Attorney

P.O. Box 12405

Austin, Texas 78711

IG/awr-File

MotLcn For Extension of Tine - Page 3