PD-1469-16 itutivtu ii\ Mr. Steven Perez OOURTOFCRIMIMAI APPEALS TDCJ-CID #1514617 Connally Unit f9f? 7R11Q Kenedy, Texas 78119 DEC 212016 December 13, 2016 AbelAcosta, Clerk Texas Court of Criminal Appeals Court Clerk, Abel Acosta P.O. Box 12308 Capitol Station Austin, Texas 78711 Re: In re Steven Perez Court of Appeals No. 13-16-00593-CR and 13-16-00594-CR Dear Court Clerk: Please file the enclosed Motion for Extension of Time to File Petition for Discretionary Review.

Thank you.

Respectfully submitted, ^—-*A *=^ Steven Perez

FSLED IN COURT OF CRIMINAL APPEALS

Abel Acosta, Cierk No.

IN RE § IN THE COURT OF STEVEN PEREZ § CRIMINAL APPEALS TDCJ-CID #1514617 § OF TEXAS

RELATOR'S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE COURT OF CRIMINAL APPEALS: Relator STEVEN PEREZ respectfully moves the Court for a 60-day exten sion of time, or until March 20, 2017, to file his petition for discretionary review, as authorized by Rules 68.2(c) and 10.5(b) of the Texas Rules of Appellate Procedure.

1. The style and numbers of this original proceeding in the Corpus Christi Thirteenth District Court of Appeals are In re1 Steven Perez, No. 13-16-00593-CR and No. 13-16-00594-CR.

2. The style and number of the case in the trial court are State of Texas v. Steven Perez, No. 07-CR-0159-B; from the 117th District Court of Nueces County, Texas.

3. The date of the court of appeals' judgment is November 2, 2016.

4. The court of appeals denied Mr. Perez's Petition for Writ of Mandamus on November 2, 2016.

5. The court of appeals denied Mr. Perez's timely filed Motion for Rehearing on December 5, 2016.

6. The present deadline for filing a petition for discretionary review under Rule 68.2(a) of the Texas Rules of Appellate Procedure is;January 4, 2017.

7. The present deadline for filing a motion for extension of time to file a petition for discretionary review under Rule 68.2(c) of the Texas Rules of Appellate Procedure is January 19, 2017.

8. The length of time requested is 60 days from the present deadline for filing a motion for extension of time to file a petition for discretion ary review under Rule 68.2(c) of the Texas Rules of Appellate Procedure.

9. The number of extensions of time previously granted regarding the item in question is none.

10. The facts relied upon to show good cause for the requested exten sion are below: (a) the petition involves complex legal and factual issues that cannot be adequately prepared before the present deadline because Mr. Perez has very limited access to the law library and the pertinent research software.

11. Mr. Perez has neither the time nor the resources to ask opposing counsel whether the State has any objections to this Motion. Nevertheless, the granting of this Motion will not be prejudicial to the State because the granting of this Motion will not undo past executed effects of the judgment and the State is not required to file a response to a petition for discre tionary review.

12. This Motion is not filed to delay these proceedings but in good faith and so that justice may be served.

13. Mr. Perez filed this Motion as soon as he became aware of the need to file it.

WHEREFORE, Relator STEVEN PEREZ respectfully moves the Court for a 60- day extension of time, or until March 20, 2017, to file his petition for discretionary review, as authorized by Rule 68.2(c) and 10.5(b) of the Texas Rules of Appellate Procedure.

SUBSCRIBED and SUBMITTED by placing in prison mailbox on this the _/J_ day of December, 2016.

Respectfully submitted,

STEVEN PEREZ,'Pro Se TDCJ-CID #1514617 Connally Unit FM 632 Kenedy, Texas 78119 DECLARATION "I, STEVEN PEREZ, TDCJ-CID #1514617, presently incarcerated at the Connally Unit in the Texas Department of Criminal Justice Correctional Institutions Division in Karnes County, Texas, declare under penalty of perjury under Chapter 132 of the Texas Civil Prac tice and Remedies Code, that the foregoing statements are true and correct and that I placed this Motion in the prison mailbox on this the yt, day of December, 2016. "EXECUTED on this the J3_ day of December, 2016." STEVEN PEREZ CERTIFICATE OF SERVICE I certify that a true and correct copy of this Motion has been served on opposing counsel on this the Jj|_ day of December, 2016, by U.S. mail through the prison mailbox, addressed as follows: James Ode11 Assistant District Attorney Nueces County Courthouse 105th Judicial District of Texas Leopard St. Room 206 Corpus Christi, Texas 78401 STEVEN PEREZ