PD-1458-15 PD-1458-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 11/9/2015 7:02:39 AM Accepted 11/10/2015 3:47:50 PM ABEL ACOSTA IN THE TEXAS COURT OF CRIMINAL APPEALS CLERK AUSTIN, TEXAS RYAN MATTHEW STAIRHIME § § VS. § CASE NO. § THE STATE OF TEXAS §

MOTION FOR EXTENSION OF TIME TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS: NOW COMES, the appellant, Ryan Matthew Stairhime, by and through his assistant public defender Jani Maselli Wood, and respectfully moves the Court to grant an additional thirty days to file the petition for discretionary review and for god cause would show: I.

Mr. Stairhime was convicted of murder and sentenced to 43 years imprisonment.

Ryan Matthew Stairhime v. State, No. 01-13-00493-CR. In a published opinion, his conviction was affirmed July 22, 2014. Stairhime v. State, 439 S.W.3d 499 (Tex. App. – Houston [1st Dist.] 2014, pet. granted). This Court granted review and reversed the First Court of Appeals. Stairhime v. State, 463 S.W.3d 902 (Tex. Crim. App. 2015). On remand, the First Court of Appeals again affirmed the conviction on October 15, 2015.

Stairhime v. State, No. 01-13-00493-CR, 2015 WL 6081596 (Tex. App. – Houston [1st Dist.] 2015, no pet. h.).

November 10, 2015 II.

The petition is due on November 14, 2015. Mr. Stairhime is requesting an additional thirty days to prepare the petition until December 14, 2014.

III.

Undersigned counsel’s reason for the request is: Briefs filed Filings and Oral Arguments: 10/28/2015 - Oral argument in Marcus Jamez Lewis v. State, 14-14-00779-CR 10/26/2015 - PDR filed in William Johnson v. State, 1254-15 10/22/2015 - Oral argument in Mary Kuol v. State, 14-14-01008-CR 10/19/2015 - Motion for Reconsideration en banc filed in Carlton Penright v. State, 01-12- 00647-CR 10/16/2015 - Motion for new trial filed in Herman Whitfield v. State, Cause Number 1424070 (This case has required numerous court appearances and is set for a hearing on November 17 & 19, 2015) 10/2/2015 - Motion for New trial filed in Jason Robinson v. State, Cause 1399192 WHEREFORE, PREMISES CONSIDERED, appellant respectfully prays that this Court grant an additional 30 days for the petition for discretionary review.

-2- Respectfully submitted,

ALEXANDER BUNIN Chief Public Defender Harris County Texas /s/ Jani Maselli Wood _______________________ JANI J. MASELLI WOOD Assistant Public Defender State Bar Number 00791195 Harris County Texas 1201 Franklin, 13th Floor Houston Texas 77002 (713) 368-0001 (713) 368-9278 (Fax) [email protected] Attorney for Appellant, Ryan Matthew Stairhime

-3- CERTIFICATE OF SERVICE Pursuant to Tex. R. App. Proc. 9.5, this certifies that on November 9, 2015, a copy of the foregoing was emailed to the Harris County District Attorney’s Office and emailed to counsel for the state and the State Prosecuting Attorney’s Office (through texfile.com) at the following address:

Alan Curry Assistant District Attorney 1201 Franklin Street, 6th Floor Houston, TX 77002 [email protected] Lisa McMinn [email protected] /s/ Jani J Maselli Wood ___________________________________ JANI J. MASELLI WOOD

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