## COURT OF CRIMINAL APPEALS
PD-1230-14 

# Chad William Murray, Appellant,
v. State of Texas, Appellee.

On Discretionary Review from No. 07-13-00356-CR Seventh Court of Appeals, Amarillo On Appeal from No. M0187-11 66th Judicial Distri ct Court, Hill County



# Motion to Extend Time to File Appellant’s Brief

Michael Mowla 445 E. FM 1382 #3-718 Cedar Hill, Texas 75104 Phone: 972-795-2401 Fax: 972-692-6636 michael@mowlalaw.com Texas Bar No. 24048680 Attorney for Appellant PD-1230-14 COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS Transmitted 12/31/2014 8:10:27 AM Accepted 12/31/2014 8:39:06 AM

ABEL ACOSTA CLERKPage 2 of 5 To the Honorable Judges of th e Court of Criminal Appeals: Appellant Chad William Murray move s for an extension of time o f 30 days to file the Appellant’s Brief:

1. On June 26, 2014, in Murray v. State , 440 S.W.3d 927 (Tex. App. Amarillo 2014), the Court of Appe als reversed and remanded Appe llant’s

conviction.

2. The State filed a petition for discretionary review, which was granted.

3. On December 18, 2014, the S tate filed its Brief.

4. Appellant’s Brief is due on January 20, 2015

. 5. For good cause, Appellant a sks for an extension of 30 days to file the Appellant’s Brief, i.e., until February 19, 2015

. 6. No previous extension to file the Appellant’s Brief has been fi led.

7. Appellant relies on the following facts as good cause for the r equested extension: First, undersigned Attorney for Appellant Michael Mo wla recently made an appearance in this case, so he is still reviewing the c ase history and

record.

8. Second, Mowla just completed a Petition for Discretionary Revie w in

State v. Moore , PD-1517-14.

9. Further, Mowla has the followi ng briefs, petitions for discreti onary review, or other pleadings due soon:Page 3 of 5  Appellant’s Brief in Little v. State , 05-14-00697-CR, Fifth Court of Appeals, due on January 4, 2015.

 Petition for Writ of Certiorari in Victorik v. Texas , Supreme Court, due on January 9, 2015.

 Petition for Discretionary Review in Johnson v. State , PD-1542-14, due on January 19, 2015.

 Response to Motion for Summary Judgment in Burress v. Blake, et al , 4-14-cv-00035-RAS-DDB, Eastern Di strict of Texas, due on Januar y 20, 2015.

 Appellant’s Brief in Von Tungeln v. State , 10-14-00329-CR, Tenth Court of Appeals, due on January 20, 2015.

 Petition for Discretionary Review in Thompson v. State , PD-1591-14, due on January 30, 2015.

 Reply Brief due in Jones v. Stephens , 4:05-CV-00638-Y, Northern District of Texas (death penalty case), due on February 6, 2015

.

 Appellant’s Brief due in Williams v. State , 05-14-01481-CR and 05- 14-01482-CR, Fifth Court of App eals, due on February 8, 2015.

10. Of particular importance is the Reply Brief in Jones v. Stephens , a death penalty case that involves numerous complex issues, and i n which the briefing has already exceeded 200 pages. The drafting of the R eply Brief has been a time-consuming project. Mowla asks for the additional 30 day s so that the drafting and filing of the Appellant’s Brief does not conflict with the timing of the due-date of the Reply Brief in Jones v. Stephens

. 11. Mowla has a responsibility to p rovide Appellant with the effect ivePage 4 of 5 assistance of appellate counsel, see Evitts v. Lucey , 469 U.S. 387, 392 (1985), and Mowla believes that that the additional 30 days is necessary to provide such effective appellate counsel.

12. This Motion is not filed for purposes of delay, but so that jus tice may

be served.
Prayer Appellant prays that this Motion for Extension of Time to File Appellant’s Brief be granted. Respectfully submitted,

Michael Mowla 445 E. FM 1382 #3-718 Cedar Hill, Texas 75104 Phone: 972-795-2401 Fax: 972-692-6636 Email: michael@mowlalaw.com Texas Bar No. 24048680 Attorney for Appellant

/s/ Michael Mowla Michael MowlaPage 5 of 5 Certificate of Service This certifies that on December 31, 2014, a true and correct c opy of this document was served on David Holmes, District Attorney, Hill Co unty, by email to dholmes@co.hill.tx.us, on Lisa McMinn, the State Prosecutin g Attorney, by email to Lisa.McMinn@spa.texas. gov and informati on@spa.texas.go v, and John Messinger, john.messinger@spa.state.tx.us. See Tex. Rule App. Proc. 9.5 (2014) and 68.11 (2014).

/s/ Michael Mowla Michael Mowla