Arreola, Jose Ismael ( 2014 )

PD-1666-14
PD-1666-14 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
December 29, 2014 Transmitted 12/22/2014 11:53:05 AM
Accepted 12/29/2014 1:14:57 PM
NO. ___________________ ABEL ACOSTA
CLERK
JOSE ISMAEL ARREOLA § IN THE COURT OF CRIMINAL APPEALS
§
v. § STATE OF TEXAS
§
THE STATE OF TEXAS § AUSTIN, TEXAS
MOTION FOR EXTENSION OF TIME
TO FILE APPELLANT’S PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF SAID COURT:
NOW COMES, the Appellant, JOSE ISMAEL ARREOLA, and moves for an extension of
time to file the Appellant’s Petition for Discretionary Review in this case, and in support thereof
would show the following:
I.
a. This case is pending below in the 195TH District Court of Dallas County, Texas under
Cause No. F12-00581-N, styled State of Texas v. Jose Ismael Arreola. It is also
pending in the Dallas Court of Appeals under case number 05-13-00181-CR.
b. Appellant was convicted of Aggravated Assault/Serious Bodily Injury/Deadly
Weapon/Family Violence and sentenced to 28 years in prison and a fine of $5,000.00.
The judgment date was February 6, 2013. On December 5, 2014, the Court of
Appeals affirmed the conviction. Appellant is currently in prison.
c. The deadline for filing the Appellant’s Petition for Discretionary Review was January
4, 2015.
d. Appellant requests an extension until February 5, 2015, to file the Petition for
Discretionary Review.
e. The reason for this request is that during the last few weeks counsel has been
working on the following:
1. Application for Writ of Habeas Corpus in Ex parte Dinesh Kumar Shah, No.
1040406, in the 182nd District Court of Harris County, Texas.
Motion for Extension of Time to File Appellant’s Petition for Discretionary Review - Page 1
2. Brief in United States v. Eseos Igiebor, No. 14-10581, in the United States
Court of Appeals for the Fifth Circuit.
3. Sentencing hearing in United States v. Raheem Abdul Shabazz, No. 3:13-CR-
026, in the United States District Court for the Northern District of
Mississippi.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully prays that this Motion
be granted.
Respectfully submitted,
/s/ Gary A. Udashen
GARY A. UDASHEN
Texas State Bar No. 20369590
SORRELS, UDASHEN & ANTON
2311 Cedar Springs Road
Suite 250
Dallas, Texas 75201
214-468-8100
214-468-8104 fax
ATTORNEY FOR APPELLANT
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing Motion for
Extension of Time to File Appellant’s Brief was electronically delivered to the Dallas County
District Attorney’s Office, 133 N. Riverfront Blvd., L.B. 19, Dallas, Texas 75207, to
michael.casillas@dallascounty.org, and electronically delivered to the State Prosecuting Attorney,
P. O. Box 12405, Austin, Texas 78711, to information@spa.texas.gov, on this the 22nd day of
December, 2014.
/s/ Gary A. Udashen
GARY A. UDASHEN
Motion for Extension of Time to File Appellant’s Petition for Discretionary Review - Page 2