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 District 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

CLERK
Page 2 of 5 

To the Honorable Judges of the Court of Criminal Appeals: 

 Appellant Chad William Murray moves for an extension of time of 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 Appeals reversed and remanded Appellant’s 

conviction. 

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

3. On December 18, 2014, the State filed its Brief. 

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

5. For good cause, Appellant asks 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 filed. 

7. Appellant relies on the following facts as good cause for the requested 

extension: First, undersigned Attorney for Appellant Michael Mowla recently 

made an appearance in this case, so he is still reviewing the case history and 

record. 

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

State v. Moore, PD-1517-14. 

9. Further, Mowla has the following briefs, petitions for discretionary 

review, or other pleadings due soon: 
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 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 District of Texas, due on January 

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 Appeals, 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 in which the 

briefing has already exceeded 200 pages. The drafting of the Reply Brief has been 

a time-consuming project. Mowla asks for the additional 30 days 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 provide Appellant with the effective 
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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 justice 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 Mowla
Page 5 of 5 

Certificate of Service

 This certifies that on December 31, 2014, a true and correct copy of this 

document was served on David Holmes, District Attorney, Hill County, by email 

to dholmes@co.hill.tx.us, on Lisa McMinn, the State Prosecuting Attorney, by 

email to Lisa.McMinn@spa.texas.gov and information@spa.texas.gov, 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