WR-71,258-03,04 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 10/29/2015 4:51:04 PM Nos. WR-71,258-03 & WR-71,258-04 Accepted 10/30/2015 7:51:32 AM ABEL ACOSTA IN THE COURT OF CRIMINAL APPEALS CLERK OF TEXAS, AT AUSTIN RECEIVED COURT OF CRIMINAL APPEALS 10/30/2015 ABEL ACOSTA, CLERK Ex parte Daniel Edward Murray Applicant Habeas Corpus Proceeding under Article 11.07, et seq., C.Cr.P., in Case Numbers W366-80173-06-HC2, and W366-80248-05-HC2, from the 366th District Court of Collin County

Agreed Motion for Stay of Proceedings

TO THE HONORABLE COURT OF CRIMINAL APPEALS: COMES NOW, Daniel Edward Murray, Applicant in the above styled and numbered cause, by and through David A. Schulman, co-counsel of record, and respectfully files this “Motion for Stay of Proceedings.” Applicant requests an approximate two-week stay in the proceedings, and in support of such request would show the Court: I The undersigned has long standing plans to be without the Country from Saturday, November 14th through and including Sunday, November 22nd, 2015. Based on the division of labor agreed upon by the undersigned and John Jasuta, Applicant’s lead counsel, the undersigned is responsible for most of the clerical work on their cases, and all federal court pleadings.

The above captioned cases are pending on the Court’s docket and subject to handdown / resolution at any time. In the event the Court rules against Applicant, he will have a very brief window in which to move into federal court. In fact, if the Court hands down these cases on either November 11 or November 18, it will be all but impossible to get the proper papers filed in federal court.

Consequently, Applicant respectfully requests that, in the interest of justice, the Court grant this request, and stay the proceedings in the above captioned cases from Thursday, November 5, 2015, through and including Monday, November 23, 2015.

II The undersigned has conferred with John Rolater, Chief of the post-conviction section of the Collin County District Attorney’s office regarding this motion. He would report that Mr. Rolater and his office agree to the granting of this motion.

Prayer WHEREFORE PREMISES CONSIDERED, Appellant prays this Honorable Court to grant this motion in all things and stay any and all action between November 5, 2015, and November 23, 2015.

Respectfully submitted,

____________________________________ David A. Schulman Attorney at Law 1801 East 51st Street, Suite 365474 Austin, Texas 78723 Tel. 512-474-4747 Fax: 512-532-6282 eMail: [email protected] State Bar Card No. 17833400 Co-Counsel for Applicant, Daniel Edward Murray

Certificate of Compliance and Delivery This is to certify that: (1) this document, created using WordPerfect™ X7 software, contains 379 words, excluding those items permitted by Rule 9.4 (i)(1), Tex.R.App.Pro., and complies with Rules 9.4 (i)(2)(B) and 9.4 (i)(3), Tex.R.App.Pro.; and (2) on October 29, 2015, a true and correct copy of the above and foregoing “Motion for Stay of Proceedings” was transmitted via the eService function on the State’s eFiling portal, to John Rolater, Jr. ([email protected]), Chief of the post-conviction section of the Collin County District Attorney’s office, and Amy Sue Melo Murphy ([email protected]), counsel of record for the State of Texas.

______________________________________ David A. Schulman