WR-82,831-01 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 3/30/2015 4:01:00 PM Accepted 3/30/2015 4:41:11 PM ABEL ACOSTA IN THE TEXAS COURT OF CRIMINAL APPEALS CLERK RECEIVED LUIS SOLIS GONZALEZ § COURT OF CRIMINAL APPEALS § 3/30/2015 ABEL ACOSTA, CLERK v. § CASE NO. ___________________ § STATE OF TEXAS § MOTION FOR EXTENSION OF TIME TO FILE REPLY TO WRIT OF MANDAMUS TO THE HONORABLE JUDGE OF SAID COURT: Comes now, Luis Solis Gonzalez, Petitioner in the above styled and numbered cause, and files this First Motion for Extension of Time to File Reply to Writ of Mandamus, and would show the Court as follows: 1. On January 9, 2015, the trial court ordered the Defendant to proceed to trial for a capital offense in which the State is seeking the death penalty before the Texas Department of Public Safety performs DNA tests of biological evidence collected as part of the investigation for the offense.

2. Counsel for Defendant requests an extension of 14 days to file Petitioner’s Reply to Writ of Mandamus. This is Petitioner’s first request for an extension of time in this case.

3. Petitioner relies on the following facts as a reasonable explanation for the requested extension of time: Counsel needs additional time in order to prepare an adequate reply to Writ of Mandamus.

4. This motion for an extension is not filed for the mere purposes of delay but so that justice may be served.

Wherefore, premises considered, the undersigned requests that the Court grant this Motion for Extension of Time for a period of 14 days from the date of filing.

Respectfully submitted, JOE A. SPENCER ATTORNEY AND COUNSELOR AT LAW 1009 Montana Ave. El Paso, Texas 79902 (915) 532-5562 (915) 532-7535 fax /s/ JOE A. SPENCER State Bar No. 1892180 JOSHUA C. SPENCER ATTORNEY AND COUNSELOR AT LAW 1009 Montana Ave. El Paso, Texas 79902 (915) 532-5562 (915) 532-7535 fax /s/ JOSHUA C. SPENCER State Bar No. 24067879

CERTIFICATE OF SERVICE The undersigned does hereby certify that a copy of the above motion was sent by hand delivery to State’s Assistant District Attorney, Denise Butterworth and to the trial court: the Honorable Luis Aguilar, 243rd District Court of El Paso County, Texas.

/s/ JOE A. SPENCER