[INSERT NAME}

Attorney at Law

[ADDRESS LINE 1]

[ADDRESS LINE 2]

State Bar No. 000000

Tel: (831) 000-0000

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SIXTH APPELLATE DISTRICT

PEOPLE OF THE STATE OF CALIFORNIA,	)

)	No. H000000

Plaintiff/Respondent,	)

)

vs.	)

)

[INSERT NAME],	)

)

Defendant/Appellant.	)

_____________________________________	)

__________________________________________

APPLICATION FOR EXTENSION OF TIME

TO FILE APPELLANT'S OPENING BRIEF

I request a 30-day extension of time to file the Appellant's Opening Brief to [DATE].

Present due date: [DATE]. No. of previous exts. One

Notice under 17(a):	has not been issued.

Date I was retained:	[DATE]

Date record filed: [DATE]. Record length 8 vols. RT 1236 , 4 Vols. CT 990. Total-- 2236. Augmentation filed [DATE] 6 Vols. RT 331

My client is in custody in state prison. Length of term: 12 years.

I need more time for the following reason(s) (specify):

A. Case Related:

This is an appeal from conviction after a jury trial involving domestic violence and lewd and lascivious conduct with a child. I finished my review of the augmentation (filed [DATE] I have written the statement of case and facts and researched most of the issues for the opening brief on appeal. Following my review of the augmentation, I discovered issues of ineffective assistance of counsel that could be raised either on appeal or in a separate habeas petition. I will have to interview trial counsel in order to determine which issues should be raised on appeal or developed in a separate habeas proceeding. This is a retained case, and the client and I have been negotiating the cost of the habeas, experts to hire, and the issues to be raised. We have almost reached an agreement on how to proceed. I am planning on having the opening brief filed within the time requested in this extension request.

I declare under penalty of perjury that the foregoing is true and correct. Executed this [DATE] , at [PLACE].

IT IS SO ORDERED:

________________________	_______________________

Presiding Justice	[ATTORNEY NAME]
Attorney at Law

[ADDRESS LINE 1]

[ADDRESS LINE 2]

State Bar No.00000

Telephone: (408) 000-0000