## SIXTH COURT OF APPEALS 06-15-00194-CR Natalie Ausbie Reynolds , Appellant v. State of Texas , Appellee On Appeal from the 354 th District Court Hunt County Cause No. 29263 

## Motion to Extend Time to File Appellant’s Brief

Michael Mowla P.O. Box 868 Cedar Hill, TX 75106 Phone: 972-795-2401 Fax: 972-692-6636 michael@mowlalaw.com Texas Bar No. 24048680 Attorney for Appellant ACCEPTED 06-15-00194-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 12/24/2015 11:39:44 AM DEBBIE AUTREY

CLERK2 To the Honorable Justices of the Court of Appeals: Appellant Natalie Ausbie Reynolds moves for an extension of ti me of 30 days to file the Appellant’s Brief [ See Tex. Rule App. Proc. 10.5(b) and 38.6(c)]:
1. This case is on appeal from th e 354th District Court of Hunt Co unty. 2. The case below is styled State v. Reynolds , and is numbered 29263.
3. Sentence was imposed in open court on October 20, 2015.
4. Appellant was convicted of Official Oppression.
5. The clerk’s record was filed on December 23, 2015.
6. The reporter’s record was f iled on December 22, 2015.
7. The Appellant’s Brief is due on January 22, 2016

. 8. Appellant requests an extension until February 22, 2016 to file the Appellant’s Brief.
9. No previous extension to file the Appellant’s Brief has been fi led.
10. Appellant relies on the following facts as good cause for the r equested extension: undersigned attorney for Appellant is presently work ing on two applications for writs of habeas corpus due to be filed by the middle of January 2016. One deals with a continuation of the underlying issues in Miller v. Alabama , 132 S.Ct. 2455 (2012). The other d eals with the sex offender r egistration statute.
11. Further, attorney for Appellant h as the following briefs, petit ions for discretionary review, or other pleadings due soon:3  Appellant’s Brief in Nguyen v. State , 06-15-00127-CR, due on January 4, 2016 in the Sixth Court of Appeals.

 Petition for Discretionary Review in Lowe v. State , PD-1427-15, due on January 4, 2016 in the Cour t of Criminal Appeals.

 Appellant’s Brief in USA v. Ziba , 15-10873, due on January 15, 2016 in the Fifth Circuit.

 Appellant’s Brief in Jack v. State , 01-15-00848-CR, due on January 18, 2016 in the First Court of Appeals.

 Appellant’s Brief in Perez v. State , 07-15-00320-CR, due on February 16, 2016 in the First Court of Appeals.
12. In addition, attorney for Appellant has been working on two com plex death penalty habeas cases - Ex parte Thomas , F86-85539, in the 194 th Judicial District Court, and Green v. Director , 3:15-cv-02197-M-BH, in the Northern District of Texas.
13. Also on January 13, 2016, attorney for Appellant has oral argum ent before the Court of C riminal Appeals in Shortt v. State , PD-0597-15.
14. Finally, during the week of Janua ry 25, 2016, attorney for Appe llant has a jury trial in a murder case in State v. Robic , F15-23573, in the 282 nd District
Court.
15. These cases are in addition to t he hearings and trial dockets o f attorney for Appellant.
16. Attorney for Appellant has a re sponsibility to Appellant to pro vide4 effective assistance of appellate counsel, see Evitts v. Lucey , 469 U.S. 387, 392 (1985), and attorney for Appell ant believes that that the reque sted additional time is necessary to provide such counsel.
17. 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 P.O. Box 868 Cedar Hill, TX 75106 Phone: 972-795-2401 Fax: 972-692-6636 michael@mowlalaw.com Texas Bar No. 24048680 Attorney for Appellant

/s/ Michael Mowla Michael Mowla5 Certificate of Service I certify that on December 24, 2015, a true and correct copy of this document was served on Hunt Count y District Attorney Nobie Walk er, 2507 Lee Street, Greenville, TX 75401, phone 903-408-4180, fax 903-408-4 296, nwalker@huntcounty.net , by email.

/s/ Michael Mowla Michael Mowla