PD-1241&1242-15 PDR MOS.

RECEIVED \U COURT OF CRIMINAL APPEALS IN THE COURT OF SEP 212015 CRIMINAL APPEALS AbelAcosta,Clerk OF TEXAS

MOWABD MA-RTIM I4ARRIS, PETITIONER VS. TME STATE OF TEXAS

FIRST MOTION FOR EXTEUSIOM OF TIME TO FILE PETITION FOR DISGHETIOHMIY REVIEW MOS. ltV-m--003c\l-CR AND l4-K-O03S2rCR IN THE COURT OF APPEALS FOR THE FOURTEENTH DISTRICT OF TEM5 TRIAL CMSE tiOS. I2CR-\B63 AMD IHGROISH- TH THE 212.™ DISTRICT COUlRT OF GALVESTON COUNTY) TEXAS FILED IN HOWARD K HARRIS, PETITIONER /PRO St court of criminal appr> T.frC/X NO. H40H22 se?-232c:j <9(5 12 STREET Abel Acosta, Cifem HUNTSVILLE, TEXAS 77348 1MM-E OF CONTEOTS page TxWe. af GonVeivls - ^_^_ Z Lis!" of Parses . 3/4 PeliVioner's (Hailon . 5 Pr ayer CefTitlcaTe. of Service . — 9

Swam DetUwrion 8 LIST OF PARTIES

Presiding Judge Honora.ble Brei Griffin Appellant Houiard Florin Vlarris Appellee The State, of Texas Attorney for Appellanf Ms, Stacy Valdez (Trial .only) lit LJ.Bay ftreaWvJ,,S\d#>

Attarn&y -far Appellant Mr. Toe\ W. BanneH (Appeal only) Sears £ Bennett, LLV 1100 l4ftSft?arWy,St5a2 Houslo(\)Te.xa& 11058 Attacrwy for Appellee Ms* CaiuLice Freemen (TcioJ only) Mr* PajulI Love (jalvesAba County Cum, District ftfW<Ws Office. kOO sq^Sfreet, Ste.lO0l GdJw°slah,Te.ia£Tl55l LIST OF PARTIES (cent.)

Attorney for Appellee Ms. Rebecca. Klaren (Appeal only") katvesfon County Criminal O'lSirict AtWneys Office. tOO 5q™ Street, Ste.\00l Galveston, TeKas 7155J

^ FIRST MOTION FOR EXTENSION OF TIKE TO FILE PETITION FOR DISCRETIONARY REVIEW TO THE UuMOflA&LE TLlbGES OF Trtt COURT OF CRIIAIWAL APPEALS; NOW COMES, HouiarJ Harris, Petitioner, pro se ana respectfully files this First Motion For Extension Df Time To File Petition For Discretionary Review- In Support of fhis notion Petitioner slnouiS the Caua the faiioLoinat 1.

Petitioner was convicted in the 2.12 District Court- of Galveston County, Galveston, Texas of -the indicted offenses Aggravated Sexual "Assau.lt and Aggravated Kidnappina in Cause. Nos. 12-CR-\&4>"3 and i4~CR-Q\54, Petitioner appealed to the l4Trt Oistrict Court of Appeals,.Houston,Texas, in ap9<2cJ cause Wos. lM-|4-D03^\-CR and W-\4-003<\l-uR. The Court of Appeals affirmed fhe conviction in each cause and issued fheir opinion on Auoasf zs] Z0\6. Court appointed Counsel for the Petitioner filed a Motion For Rehearing- uitK fhe 14Tl4 District Court of f^eals.The Motion for Rehearing uias denied uiVVhout opinion Se.9te.mDer, 10 Z01S.

II- The present deadline for filing -fhe Dexrfion For Discretionary ftevieu; is October iOrHZO!5. Petitioner h«as not recjueSTed any extension prior to this request.

TTT.

Petitioners request for an extension is based upon fhe following facts: \)Petitioner did nof receive notice of the Court of Appeals' decision on the Motion For Rehearing until I September I6™#>I5: 2) Court appointed counsel for appeal, loel H- Bennett has issued notice that he ujill not be representing Petitioner in fhe filing of fhe ?etition for Discretionary Review. Thusly, Petitioner mast proceed in the appeal process pro se, DrVftioner lacks sufficent knowledge, of legal procedures and document" formats to meet the Current October \o\l 1015 deadline to file the Petition For Discretionary Review, 4.) Petitioner has limited access to the La-ui Library at fhe TDCI unit Lubere Vie is incacerated* 53The TDC3 unit where Petitioner is Currently incarcerated has a scheduled bi-annual inventory due to take place uoifhin the next thirty days, durir\q ujhich time the unit uaill be on lock-doujn for a period of 7-k>i4 days. Petitioner u/iU not have access to the unit Lau> Library for the duration of this iock-douon.

For the foreqoing reasons, Petitioner respectfully requests this Honorable Court to extend fhe deadline for filing the Petition For Discretionary Revieio in Court of Appeals Cause Mos. W-i»J-003qi-CR and m-m- 003^12-CR by thirty (30) days to November lO^ZoiS", in order that Petitioner may have sufficent time to properW format" and file the Petfion For Discretionary Review, PRAYER WHEREFORE, PREMISES COMSlftERED, Petitioner prays that fhe Court of Criminal ftppeals grant his First Motion For Extension Of Time To File Petition Fof Discretionary Revieu). l?espectfu\ly Submit\el,

Uouxxrd tWuS TDC3 Mo. MoU2 TDCT / HunW.lW Unit 8i5 I2TH Street Huntsv/i lie, Texas TJ318

CERTIFICATE Of SERVICE - I hereby certify that on September \%\ 2015, a true and correct copy of Petitioner's First Motion For Extension Of Time To File Petition For Discretionary P\ev^eu3 to be filed in the Court Of Criminal repeats has been forwarded by LLS, Mail, postage prepaid, first class, to Attorney for State, "Rebecca Klaren* in Care of the Galveston County Criminal District Attorneys Office at LOO 5^ Street, SteTuOl;(aa\veston, Texas 1155/, and to the State Prosecuting Attorney, P.O. &ox I2405, Austin,Texas 18111 on this the l9TVy of September 2015. . , ,

SWORN DECLl\ft(\TIQrt X, Howard \dauis,T0C3 tto. iWO^n, being present/ incarcerated in the ItuntsviUe Unit of the Texas Depart- -me.nt of Criminal Tustice-Insf national Division in Walker CouvAy, Texas, verify Ckt\A declare under penalty of perjury that tbe. foregoing statements are, true and Correct. Executei on this the \fiTV* do.y of September, Z0\S- / aI

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