* PD-0064&0065&0066&0067-15 John Brown From: R. Scott Shearer <[email protected]> «£*{/ <J tf^y'V k< Sent: Thursday, February 12, 2015 9:57 AM To: John Brown Subject: Emergency motions to extend brief, PDR's Attachments: Picturel.jpg; Picture2.jpg; Picture3.jpg; Picture4.jpg; MP- shea^r^^Jj^jeDOrt^^ FEB 12 2015 Dear Mr. Brown, Abel Acosta. Cler I am writing to request an emergency motion to extend time to file brief in the case of Juan Balderas v. State of Texas No. AP-77,036 (past due January 20) and emergency motions to extend time to file PDR in the cases of Raymond Buchanan PD-0063-15 and Wydell Dixon PD-0064-15, 0065, 0066, 0067 (both currently due February 16). I am currently in the hospital. The hospital information is as follows: FILED IN College Station Medical Center C0URT QF CR|M|NAL APPEALS 1604 Rock Prairie Road College Station, TX 77845 FEB 12 2015 (979) 764-5100 Room 282 Abel Acosta, Clerk The saga with my foot began in October of last year. I wore some ill-fitting boots which rubbed a spot on the bottom of my foot that was the site of an old plantar wart. This caused an infection of the foot, (picture 1). The first doctor successfully treated the surface infection with antibiotics. However, two abscesses remained on the bottom of the foot, (picture 2). Treatment was attempted with 2 different sets of antibiotics and then 2 outpatient surgeries to pack the abscesses. Even though 2 cultures turned up negative, treatment proved unsuccessful, (picture 3). In January, Iwas given an MRI (see attached) and it was discovered that the infection had spread into the bones ("Osteomyelitis"). On February 9th Iwas admitted to the hospital and on February 10th I underwent surgery. The two sesamoid bones on the bottom of my foot were removed along with about a %inch of bone from the joint and portions of diseased tendon. This morning the culture from the bones came back positive for staph. They are running further tests to determine if the infection is MRSA, an antibiotic resistant form of staph infection. I have been given multiple IV antibiotics at the hospital, (picture 4). I was told this morning that upon my release from the hospital, I will be required to undergo a further 6 weeks of IV antibiotics at home and will have an external catheter for this purpose. I will also be non-weight bearing with respect to the foot Since October, I have seen 1 physician's assistant, 1 general outpatient surgeon, 1 podiatrist, 2 pathologists and 1 endocrinologist. This does not include the physician staff at the hospital. I have also lost 20 pounds. Since October I have not been able to walk except for short distances and only with difficulty.

Because of the throbbing pain, I cannot sit down either unless my foot remains elevated. I have been able to work on a limited basis by using a computer while lying in bed. I was able to complete and file a pro bono PDR in the case of ValdemarBautista (PD-1657-14) on January 28. However, I have discovered that writing in bed is a much slower process than writing at my desk. As a result of this limitation, as well as the time required to visit doctors, grogginess from medication, and the disruptions in my sleep, I have fallen behind schedule with my briefs. I estimate that the Balderas brief is approximately 85% done. The Buchanan PDR is 50% complete V and the Dixon PDR I have not yet begun. I would appreciate any further time that could be given to complete these tasks and I thank you for your kind attention to this matter.

Sincerely, R. Scott Shearer