Case Information

*1 PD-1676-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 12/28/2015 2:38:50 PM Accepted 12/29/2015 3:36:24 PM ABEL ACOSTA PD._________________ CLERK IN THE COURT OF CRIMINAL APPEALS FOR THE

STATE OF TEXAS

JERIMIAH BAREFIELD

V. Appeals No. 04-14-00699-CR THE STATE OF TEXAS

MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:

COMES NOW, ANGELA MOORE, counsel for JEREMIAH BAREFIELD, and files this motion asking that the Court extend the time for filing the Appellant’s petition for discretionary review, and in support thereof, offers the following: This case is on appeal from the 227 TH District Court of Bexar

County, Texas. The style and number of the cases in the trial court are The State

of Texas v. JERIMIAH BAREFIELD , Cause Number 2012-CR- 6188A. The Appellant was convicted by the Court of the offense of

murder. Punishment was assessed by the jury at Life in the Texas

Department of Criminal Justice – Institutional Division. *2 The style and number of the case in the Fourth Court of Appeals

is JERIMIAH BAREFILED v. State of Texas , Appeal Number 04- 14-00699-CR. The Fourth Court of Appeals affirmed Appellant’s conviction and

sentence in an upublished opinion on November 25, 2015. The present deadline for filing the Appellant’s Petition for

Discretionary Review is December 28, 2015. The Appellant seeks an extension of time of 30 days, suggesting a

new due date of January 27, 2016. i. This is the Appellant’s first request for an extension of time to file

the Appellant’s petition for discretionary review.

II. This extension is not sought for the purpose of delaying this appeal, but for the following reasons: Counsel has recently completing briefing in the

following cases: The State of Texas v. Brandon Garzas, 2015-JUV-00638 &

2015-JUV-00641, Motion for New Trial, filed September 24, 2015; Orvil Weddel v. State, 07-15-00302-CR, Petition for

Discretionary Review; Eduardo Ruiz v. State, 2007-CR-4886W1, Writ of Habeas

Corpus, filed October 14, 2015 & Memorandum on Writ of Habeas Corpus, filed October 29, 2015; *3 II. Counsel is currently completing briefing in the following cases: Reynaldo Garcia v. State, Writ of Habeas Corpus Daniel Garcia v. State, Writ of Habeas Corpus Joshua Chris Meadoux v. State, Writ of Habeas Corpus The United State of America v. Jeffrey Perry, 15-50973; The United States of America v. Jeremiah Martinez, 14-

CR-00977(1)-OLG Perry Mayfield v. State; 04-14-00274-CR, Writ of Habeas

Corpus; Oscar Guevara-Mata v. State; 04-12-00436-CR, Writ of

Habeas Corpus Charles Finch v. State; 04-15-00502-CR

III. A criminal appellant, just like a criminal defendant at trial, is entitled to the adequate and effective assistance of counsel. Evitts v. Lucey , 469 U.S. 387, 396 (1985); Ward v. State , 740 S.W. 2d 794 (Tex.Crim.App.

1987). In order to be able to accurately identify and effectively brief all the potential issues presented in this case, counsel for Appellant needs additional time to review the record and conduct the necessary research to adequately prepare Appellant’s Petition for Discretionary Review. This

request is made pursuant to Tex. R. App. P. 68.2 (c).

IV. Therefore, for the above reasons, Counsel for Appellant prays that the Court grant an extension of time to January 27, 2016, for filing of the Appellant’s Petition for Discretionary Review. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing Motion for Extension has been delivered to the Bexar County District Attorney’s Office, 300 Dolorosa, San Antonio, Texas 78205, on December 28, 2015.