IN THE COURT OF CRIMINAL APPEALS EX PARTE § § § § WRIT NO. _________________ JASON MATTHEW TRUVER § TRIAL NO . C-371-010503-0743445-A FIRST MOTION FOR EXTENSION OF TIME FOR RESOLUTION OF ISSUES AND SUBMISSION OF WRIT RECORD TO THE HONORABLE COURT OF CRIMINAL APPEALS: COMES NOW, the 371 ST Judicial District Court of Tarrant County Texas and

moves this Court t o grant an additional forty

- five (45) day extension of time for resolution of the issues and submit the writ record in this case. The following allegations are made in support of this motion:
I. PROCEDURAL HISTORY On August 30, 2001 , JASON MATTHEW TRUVER (“Applicant”), was convicted by a jury of the first degree felony offense of possession with intent to deliver a controlled substance of four grams or more, but less than 200 grams, namely: methamphetamine

. The jury made an affirmative deadly weapon finding and assessed punishment at forty

- five years confinement in the Texas Department of Criminal Justice – Institutional Division.
On May 1 6, 2002, the Third Court of Appeals affirmed the trial court’s

1 WR-84,352-01 COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS Transmitted 12/16/2015 9:44:20 AM Accepted 12/18/2015 4:26:13 PM

ABEL ACOSTA CLERKjudgment on May 16, 2002. See Truver v. State , No. 03

- 01

- 00569

- CR, 2002 WL 990996 (Tex. App.

– Austin May 16, 2002, no pet.) (not designated for publication). On June 22, 2015, Applicant filed this application for writ of habeas corpus. The State was served on that date.
T he trial court’s 180 day deadline to resolve the issues in this application for writ of habeas corpus is December 21 , 201 5 , because December 19, 2015, is a Saturday

. See Tex. R. App. 73.5.

II. AN ADDITIONAL FORTY
- FIVE DAY EXTENSION IS REQUESTED The trial court requests that this Court grant an additional forty

- five ( 45 ) day extension of time for resolution of the issues and submit the writ record in this application. I f this extension is granted, the resolution of the issues would be accomplished on or before February 2, 2016 , and the writ record submitted on or before February 3, 2016

. This extension is not sought for purposes of delay. Additional time is needed to d etermine resolve Applicant’s issues

. WHEREFORE, PREMISES CONSIDERED, the trial court prays that this Court grant a n additional forty

- five ( 45 ) day extension for resolution of the issues in this case

2and order that the issues be resolved by on or before F ebruary 2, 2016 , and the writ
record submitted on or before February 3, 2016

. Respectfully submitted,

/s/ CHARLES P. REYNOLDS CHARLES PATRICK REYNOLDS Judicial Staff Counsel and Post

- Conviction Magistrate Tarrant County, Texas 401 W. Belknap Fort Worth, Texas 76196 (817) 884

- 2326 Fax (817) 884

- 2312 State Bar No. 00789580

3CERTIFICATE OF SERVICE A true copy of the above First Motion for Extension of Time for Resolution of Issues has been hand

- delivered to Hon. Andréa Jacobs , Assistant Criminal District Attorney, Tarrant County District Attorney’s Office and mailed to Applicant, Mr. Jason Matthew Truver, TDCJ

- ID# 1061122 , Connally Unit, 899 FM 632, Kenedy, Texas 78119 on the 16 th day of December , 201 5

.

/s/ CHARLES P. REYNOLDS CHARLES PATRICK REYN OLDS

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