SIXTH COURT OF APPEALS 

06-15-00194-CR 

Natalie Ausbie Reynolds, Appellant 

v. 

State of Texas, Appellee 

On Appeal from the 354th 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

CLERK

 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 12/28/2015 9:07:00 AM DEBBIE AUTREY Clerk
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To the Honorable Justices of the Court of Appeals:

 Appellant Natalie Ausbie Reynolds moves for an extension of time 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 the 354th District Court of Hunt County. 

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 filed 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 filed. 

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

extension: undersigned attorney for Appellant is presently working 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 deals with the sex offender registration statute. 

11. Further, attorney for Appellant has the following briefs, petitions for 

discretionary review, or other pleadings due soon: 
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 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 Court 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 complex 

death penalty habeas cases - Ex parte Thomas, F86-85539, in the 194th 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 argument 

before the Court of Criminal Appeals in Shortt v. State, PD-0597-15. 

14. Finally, during the week of January 25, 2016, attorney for Appellant 

has a jury trial in a murder case in State v. Robic, F15-23573, in the 282nd District 

Court. 

15. These cases are in addition to the hearings and trial dockets of 

attorney for Appellant. 

16. Attorney for Appellant has a responsibility to Appellant to provide 
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effective assistance of appellate counsel, see Evitts v. Lucey, 469 U.S. 387, 392 

(1985), and attorney for Appellant believes that that the requested additional time 

is necessary to provide such counsel. 

17. 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 

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 Mowla 
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Certificate of Service 

I certify that on December 24, 2015, a true and correct copy of this 

document was served on Hunt County District Attorney Nobie Walker, 2507 Lee 

Street, Greenville, TX 75401, phone 903-408-4180, fax 903-408-4296, 

nwalker@huntcounty.net, by email. 

 /s/ Michael Mowla 

Michael Mowla