Case Information

*1 PD-1057-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 8/13/2015 10:32:19 AM Accepted 8/17/2015 1:37:18 PM ABEL ACOSTA NO. 14-14-00262-CR CLERK IN THE COURT OF APPEALS FOURTEENTH DISTRICT HOUSTON, TEXAS NO. 1416917

IN THE TRIAL COURT 180 TH JUDICIAL DISTRICT HARRIS COUNTY, TEXAS ISMAEL TREVINO § APPELLANT

VS. §

THE STATE OF TEXAS § APPELLEE

MOTION FOR EXTENSION OF TIME FOR FILING PETITION FOR DISCRETIONARY REVIEW 2016 Main St., Suite 110 Houston, Texas 77002 713/236-1000 Fax No. 713/236-1809 STATE BAR NO. 10431500 Email: allenisbell@sbcglobal.net COUNSEL ON APPEAL *2

TO THE HONORABLE COURT OF CRIMINAL APPEALS:

COMES NOW ISMAEL TREVINO, appellant, by and through his counsel on appeal, ALLEN C. ISBELL, and respectfully requests this Honorable Court grant an Extension of Time for Filing a Petition for Discretionary Review.

I. The Fourteenth Court of Appeals in Houston, Texas, delivered an opinion in this matter on July 23, 2015, in Cause No. 1416917, entitled ISMAEL TREVINO vs. The State of Texas .

II. The present deadline for filing the Petition for Discretionary Review is August 22, 2015.

III.

Appellant requests that the time be extended until September 21, 2015.

IV. Counsel is unable to timely file the Petition for Discretionary Review within the time prescribed by the TEXAS RULES OF APPELLATE PROCEDURE for the following reasons:

1. Counsel is preparing for the following Trials:

• State vs. Aguilar, Cause No. 1370058 (Murder)(set to begin

August 17, 2015); • State vs. Earls, No. 1388874 (Capital Murder)(set to begin

September 8, 2015); • State vs. Pinnock, Nos. 1435200 & 1393885 (Aggravated

Assault with a Deadly Weapon & Evading Arrest).

2. Counsel has recently represented the following in court: State vs.

Allen, Nos. 1475254 & 1403306; State vs. Block, Nos. 1477559 & 1477560;State vs. Bonds, No. 1436427; State vs. Barnaba, No.

1470729; State vs. Bell, No. 1458279; State vs. Davis, No.

1438664; State vs. Dornes, No. 1477372; State vs. Dow, Nos.

1470185 & 1470186; State vs. Dudley, No. 1475827; State vs.

Earls, Nos. 1466223, 1466229, 1466318, & 1466692; State vs.

Ellis, Nos. 1473854 & 1473855; State vs. Harris, No. 1471752; State vs. Hastings, No. 1464287; State vs. Hornsby, Nos.

1455466, 1455467 & 1455768; State vs. Magee, Nos. 1392085, 1386835, 1387732, & 1386809; State vs. Monroe, No. 1470489; State vs. Morris, No. 1458287; State vs. Perez, No. 1448860; State vs. Perkins, No. 1459848; State vs. Pinnock, Nos. 1435200 & 1393885; State vs. Sylmon, No. 1467313; State vs. Rodriguez, No. 1464967; State vs. Ward, Nos. 1284273, 1297205, & 1297206;

V.

This is the first (1) extension requested.

VI. This motion is urged at the first opportunity as appellant is indigent and will suffer irremediable harm if it is not granted.

WHEREFORE, PREMISES CONSIDERED, appellant prays that this Honorable Court grant this extension of time in which to file the Petition for Discretionary Review until September 21, 2015.

Respectfully submitted, /s/ Allen C. Isbell ALLEN C. ISBELL 2016 Main St., Suite 110 Houston, Texas 77002 713/236-1000 Fax No. 713/236-1809 STATE BAR NO. 10431500 Email: allenisbell@sbcglobal.net COUNSEL ON APPEAL Certificate of Service I hereby certify that on this 13 th day of August, 2015, a true and correct copy of the foregoing Motion for Extension of Time for Filing Appellant's Petition for Discretionary Review has been sent to the District Attorney's Office, Appellate Division, and to Mr. Ismael Trevino, appellant.

/s/ Allen C. Isbell *5 Certificate of Compliance The undersigned attorney on appeal certifies this motion is computer generated and consists of 572 words. Counsel is relying on the word count provided by the Word Perfect computer software used to prepare the motion.

/s/ Allen C. Isbell