PD._________________
IN THE COURT OF CRIMINAL APPEALS

FOR THE STATE OF TEXAS
WALTER EARL TAYLOR V. Appeals No. 01-11-00210-CR
THE STATE OF TEXAS
MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR

DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS: COMES NOW, David Suhler, counsel for WALTER EARL TAYLOR, and files this motion asking that the Court extend the time for filing the Appellant’s petition for discretionary review, and in support thereof, offers the following:
I.

a. This case is on appeal from the 56th District Court of Galveston County, Texas. b. The style and number of the case in the trial court is The State of Texas v. Walter Earl Taylor, Cause Number 10CR1215.

c. The Appellant was convicted by the Jury of the offense of possession of cocaine weighing between four (4) and two hundred (200) grams. d. Punishment was assessed by the Jury at 25 years confinement in the Texas Department of Criminal Justice – Institutional Division.

e. The style and number of the cases in the First Court of Appeals is Walter Earl Taylor v. State of Texas, Appeal Number 01-11-00210-CR. PD-0315-15 COURT OF CRIMINAL APPEALS

AUSTIN, TEXAS Transmitted 3/23/2015 12:00:00 AM Accepted 3/25/2015 1:07:03 PM

ABEL ACOSTA CLERKf. The First Court of Appeals granted Appellant's moti on for rehearing on

September 3, 2014 and then re-affirmed Appellant’s conviction and sentence in a published opinion on February 19, 2015.
g. The present deadline for filing the Appellant’s Pet ition for Discretionary Review is March 21, 2015, a Saturday, thus making M arch 23, 2015 the deadline. h. The Appellant seeks an extension of time of 30 days , suggesting a new due date of April 22, 2015. i. This is the Appellant’s first request for an extens ion of time to file the Appellant’s petition for discretionary review.
II. This extension is not sought for the purpose of de laying this appeal, but relies on the following facts to reasonably explain the need for an extension:

1. Counsel for Appellant is currently completing brief ing in other cases, causing a delay to adequately research and brief th e referred cases by the deadline. Within one (1) week of the opinion from the First Court of Appeals, that court issued its rulings in a complex set of cases for which PDR will also be sought. This matter has been on h old for over six (6) months while the First Court of Appeals decided the motion for rehearing and considerable time will be required for counsel to become familiar with the issues again.2. Counsel for Appellant recently experienced a hung j ury in a District Court case and now must re-prepare for trial in that matt er. III. A criminal appellant, just like a criminal defenda nt at trial, is entitled to the adequate and effective assistance of counsel. Evitts v. Lucey , 469 U.S. 387, 396 (1985); Ward v. State , 740 S.W. 2d 794 (Tex.Crim.App. 1987). In order to be able to accurately identify and effectively brief all the potential is sues presented in this case, counsel for Appellant needs additional time to review the recor d and conduct the necessary research to adequately prepare Appellant’s Petition for Disc retionary Review. This request is made pursuant to T EX

. R. A PP

. P. 68.2 (c).
IV. Therefore, for the above reasons, Counsel for Appe llant prays that the Court grant an extension of time to April 22, 2015, for filing of the Appellant’s Petition for Discretionary Review. Respectfully submitted, 

### David Suhler___________ DAVID SUHLER Attorney for Defendant State Bar No. 19465900 P.O. Box 540744 Houston, Texas 77254-0744 (713) 522-1220CERTIFICATE OF SERVICE

I certify that a true copy of the above motion was delivered by email to Ms. Allison Lindblade with the Office of the Criminal D istrict Attorney of Galveston County TX on March 20, 2015. 

### David Suhler __________ DAVID SUHLER