NO. IN THE COURT OF CRIMINAL APPEALS AUSTIN, TEXAS 

### FILED IN COURTOFCRIMINALAPPEALS 

### OCT 082015 AbelAcosta, Clerk ISAAC GONZALEZ, Petitioner, V. THE STATE OF TEXAS Respondent. KeCb 

### a 

# COURTOFOR'»'AL£PPais OCT082015

• ^DelAcoma,Qmk

FromAppealNo. 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 HONORABLEJUSTICES OF THE COURT OF CRIMINAL APPEALS: 

### COMESNOW, IsaacGonzalez, "Petitioner," pro se, andfiles 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 ofVictoria County, 

### Texas, in Cause No. 12-3-26,449-A, styled State of Texas vs. Isaac Gonzalez. On June 12, 2015, Petitioner filed amotion with the trial court, requesting appoint ment of counsel for habeas corpus, titled DEFENDANT'S MOTION FOR APPOINTMENT OF COUNSEL FOR HABEAS CORPUS, UNDERTEXAS FAIR DEFENSE ACT, ARTICLE 1.051 V.A.C.C.P. 

### On June 19, 2015, Petitioner's motionwas denied by the trial court, without an 

### explanation of why. Petitioner timely filedNotice of Appeal, onJune 15, 2015, 

### appealing to the Court of Appeals for theThirteenth (13th) Judicial District of Texas. Said Court of Appeals dismissed the appeal forwant of jurisdiction on September 3, 2015.

MationForExtensicn ofTime
- Rage 1II. 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 anattorney to handle this litigation; and the matter being appealed is somewhat new, requiring anextensive 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 hemay be entitled. I, Isaac Gonzalez, TDCJ No. 1809453, being presently incarcerated at the French M. Robertson unit of the Texas Department of Criminal Justice inJones Cou 

### nty, Texas; dohereby verify and declare under penalty of perjury that the forego ing is both true and correct, as well as offered ingood faith. 

### [Tex.Civ.Prac.&Rem.Code § 132.001-003 et seq./Title 28 U.S.C.§ 1746] (Asigned/datedcopyof thisM3EDCNshallhavethesamevalidityas itsoriginal) 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

MotionForExtensionofTime
- Page 2CERTIFICATE 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 FORDISCRETIONARY 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 29thday 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

MotLcnFor Extension of Tine - Page 3