No. ______________________



## IN THE COURT OF CRIMINAL APPEALS

OF TEXAS

CHRISTOPHER NJOKU, Petitioner–Appellant

v.

THE STATE OF TEXAS, Respondent–Appellee

Petition for Discretionary Review from the Fifth District Court of Appeals at Dallas

Cause No

. 05-14-01201-CR

Appeal from County Criminal Court No. 9 of Dallas County, Texas Cause No

. MA13-16684-K

MOTION FOR EXTENSION OF TIME TO FILE A PETITION FOR DISCRETIONARY REVIEW

Christopher Njoku, Appellant below, respectfully submits this Motion for

an Extension of Time to File a Petition for Discretionary Review in the above–

styled and numbered cause. In support of this Motion, he shows this Honorable

Court the following: PD-1643-15 COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS Transmitted 12/18/2015 10:54:55 AM Accepted 12/19/2015 10:12:28 AM

ABEL ACOSTA CLERK2 I.

A jury convicted Appellant for resisting arrest. T he court sentenced him to

90 days’ confinement in the county jail, but probat ed the sentence and placed him

on community supervision for a period of six months

.

II.

The Court of Appeals affirmed the trial court’s ju dgment in a memorandum

opinion and judgment filed on November 18, 2015. Njoku v. State of Texas , No.

05-14-01201-CR, 2015 Tex. App. LEXIS 11841 (Tex. Ap p.—Dallas Nov. 18,

2015). Appellant did not file a motion for reheari ng. Appellant’s petition for

discretionary review is due on December 18, 2015. See Tex. R. App. P. 68.2(a);

see also Tex. R. App. P. 4.1(a). Any motion for extension of time to file a petition

for discretionary review is due on January 2, 2016

. See Tex. R. App. P. 68.2(c);

Tex. R. App. P. 4.1(a).

III.

The facts relied upon to show good cause for this r equested extension are as

follows:

1. Appellant was represented by court appointed counse l during appeal of this case to the Court of Appeals.

2. It is undetermined at this time whether Appellant w ill proceed pro se for purposes of filing a Petition for Discretionary Rev iew. Additional time is needed for consultation between appellate counsel a nd Appellant on this issue.3

3. If Appellant proceeds pro se, then additional time will be needed to prepare and file the Petition pro se or to seek oth er legal assistance in filing the Petition.

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully

requests that this Honorable Court extend the time for filing a Petition for

Discretionary Review for thirty days.

Respectfully submitted,

Lynn Richardson Chief Public Defender Dallas County

Katherine A. Drew Chief, Appellate Division Dallas County Public Defender’s Office

/s/ Julie Woods Julie Woods Assistant Public Defender Dallas County Public Defender’s Office State Bar Number: 24046173 133 N. Riverfront Blvd., LB 2 Dallas, Texas 75207 (214) 653-3550 (telephone) (214) 653-3539 (fax) Julie.Woods@dallascounty.org

Attorneys for Petitioner4 CERTIFICATE OF SERVICE

I certify that a true copy of the foregoing Motion for Extension of Time to File a Petition For Discretionary Review was served on Larissa Roeder, counsel for the State, Dallas County District Attorney’s Office , 133 N. Riverfront Blvd., LB19, 10th Floor, Dallas, Texas 75207, by eServe on D ecember 18, 2015.

I further certify that a true copy of the foregoin g Motion for Extension of Time to File a Petition For Discretionary Review wa s served on Lisa C. McMinn, the State’s Prosecuting Attorney, P.O. Box 13046, C apitol Station, Austin, Texas 78711, by eServe on December 18, 2015.

/s/ Julie Woods Julie Woods