PD-1100-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 9/21/2015 12:00:00 AM September 22, 2015 Accepted 9/22/2015 1:02:15 PM ABEL ACOSTA No. PD-1100-15 CLERK In the COURT OF CRIMINAL APPEALS ______________________________________ On Appeal from the 404th Judicial District Court of Cameron County, Texas in Cause Number 10-CRF-727G; and the Opinion of the Thirteenth Court of Appeals in Cause Number 13-13-00172-CR, Delivered July 23, 2015 ______________________________________ ABRAHAM JACOB PROENZA v. THE STATE OF TEXAS _____________________________________ MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO PETITION FOR DISCRETIONARY REVIEW ______________________________ TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS: COMES NOW, Kristen Jernigan, the undersigned attorney of record for Abraham Jacob Proenza, the Appellant, herein, and files this Motion for Extension of Time to File Response to Petition for Discretionary Review. As set out below, the undersigned respectfully requests a thirty-day extension to file Appellant’s Response to the State’s Petition for Discretionary Review. In support of said motion, the undersigned would show the Court the following: 1. Appellant’s Response to the State’s Petition for Discretionary Review is currently due in this case on September 23, 2015.

2. Appellant seeks an extension of thirty days in which to file his Response to the State’s Petition for Discretionary Review, making his Petition due on or before October 23, 2015.

3. The undersigned is currently in a murder trial in the cause of The State of Texas v. Daniel Willis, No. 15,605 in the 21st District Court of Bastrop County.

The proceedings began September 14, 2015, and are expected to last through September 22, 2015 at the very least. Additionally, in the past thirty days, the undersigned has filed a brief in the First Court of Appeals in Cause Number 01-14-01023-CR, Sean Michael McGuire v. The State of Texas. Further, on September 9, 2015, the undersigned was the attorney of record in a contested hearing in the Capital Murder case of Cornelius Harper v. The State of Texas, No. 01-14-00641-CR. Moreover, on September 8, 2015, the undersigned traveled to Cameron County for an appearance in the trial court on the present case to comply with this Court’s orders regarding setting the conditions of Appellant’s bail.

Finally, the undersigned has undertaken the tasks associated with a solo practice.

Consequently, the undersigned respectfully requests that the Court grant Appellant the additional time.

4. The undersigned has not filed any previous motions for extension of time in this case.

5. For the reasons set forth above, the undersigned respectfully requests that Appellant be granted an extension of thirty days so that his response in this case will now be due on October 23, 2015.

PRAYER WHEREFORE, PREMISES CONSIDERED, the undersigned respectfully requests that this Court grant this Motion for Extension of Time to File his Response to the State’s Petition for Discretionary Review.

Respectfully submitted,

_______/s/__Kristen Jernigan______ KRISTEN JERNIGAN State Bar Number 90001898 S. Austin Ave. Georgetown, Texas 78626 (512) 904-0123 (512) 931-3650 (fax) [email protected]

CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing Appellant’s Motion for Extension of Time has been emailed to the State Prosecuting Attorney’s Office, [email protected], on September 20, 2015.

__/s/ Kristen Jernigan__________________ Kristen Jernigan