Jackson, Walter Louis Jr.

PD-0605&0606&0607&0608-16 NO. 14-15-00244-CR NO. 14-1 5-00245-CR ~~n' OFQr^' vt=U //\/ NO. 14-15-00246-CR ^LAPr NO. 14-15-00247-CR ^(.g FILED IN in the A^y5i COURT OF CRIMINAL APPEALS court of criminal appeals {'\\QolZ\2 WALTER LOUIS JACKSON, JR. •*""' Appellant Abel Acosta, Clerk THE STATE OF v• TEXAS Abe,A^olerk Appellee APPEAL'. FROM^ THE 26Bth DISTRICT COURT OF FORT BEND COUNTY, TEXAS TRIAL COURT CAUSE NUMBERS 12-DCR-062008 ; 12-DCR-062010; 12-DCR-062011; 12-DCR-062012 APPELLANT'S FIRST MOTION FOR EXTENSION OF TIME TO FILE P.D.R WALTER- LOUIS JACKSON, JR TDCJ-ID* 1982B26 BETO UNIT 1391 FM 332B TENN COLONY TX 75BBO Ifol T;T:.HE COURT OF CRIMINAL APPEALS WALTER LOUIS JACKSON, JR, Appellant v . THE STATE OF TEXAS, Appellee :-TD THE HONORABLE JUDGES OF SAID COURT: THE STATE OF TEXAS, Appellant, moves for an extension of SIXTY (60) days in which to file a P.D.R. pursuant to TEX. R. APP. P. 10..5(b) and shousi Pursuant to TEX. R. APP. P. 10.5(b), Appellant, moves this Court to allow an extension of SIXTY (60) days to file his brief. Appellants convictions were affirmed by the Fourteenth Court of Appeals on May 5th, 2016 and pursuant to TEX. R. APP. P. 6B. Appellant is preparing his petition for discretionary review II. REQUIRED INFORMATION PURSUANT TO THE RULES OF APPELLATE PROCEDURE The deadline for filing the extension. TEX. R. APP. P. 10.5 (b) (1 )(A) : June 5, 2016. TEX. R. APP. P. 3B.6(D):"A motion to extend the time to file a brief may be filed before or after the date the brief is due." The length of the extension sought. TEX. R. APP. P. 10.5(b) (1 )(B) : Sixty (60) days. The facts relied upon to reasonably explain the need for the extension. TEX. R. APP. P. 10.5(b)(1)(B): Appellant has no experience in pro se litigation and is working with jailhouse lawyers to get some assistance in this matter. Additionally, Appellant is attending the Beto Unit law library to hopefully prepare a congent P.D.R. in this matter. The sixty (60) days extension should be adequate to complete the P.D.R. Number of previous extensions granted for previous Motions for Extension. TEX. R. APP. P. 10.5(b)(1)(D): NONE III. The additional time requested is not sought solely for delay nor sought frivolously, but will be of genuine assistance to Appellant's preparing petition for discretionary review. WHEREFORE, Appellant prays that the Court grant this Motion and modify and extend the deadliine for filing Appellant's petition for discretionary review to July 27, 2016, or that this Court grant such additional time as is just and_ proper. Respectfully submitted, Walter Louis Jackson, Jr TDCJ ID# 19B2B26 Beto Unit 1391 FM 332B Tennessee Colony, TX 75B80 CERTIFICATE£OF SERVICE This is to certify that a true and correct copy of the above and foregoing motion for Appellant has this day been sent by U.S. Postal Services to State's Attorney for Appellant on Walter Louis Jackson, Jr WALTER LOUIS JACKSON, JR, Appellant IN THE COURT OF CRIMINAL APPEALS, AUSTIN THE STATE OF TEXAS, Appellee ON APPEAL FROM THE FOURTEENTH COURT OF APPEALS NO. 14-15-00244-CR; NO. 14-15-00245-CR; NO. 14-15-00246-CR ON APPEAL FROM. THE 26BTH DISTRICT COURT, FORT BEND COUNTY, TTX Trialicourt case nos. 12-DCR-06200B; 12-DCR-062010; 12-DCR-062011; and, 12-DCR-062012 Appellant's pro se Motion to Suspend Rule 9.3(b). TEX.RiAPP. P. TO THE HONORABLE JUDGES OF THE COURT: COMES NOW Walter Louis Jackson, Jr, and moves the Court to grant this, his Motion to Suspend Rule 9.3(b). TEX.R.APP.P. and allow Appellant to file onev(T) copy of his P.D.R. Fort,the fallowing reasons: Appellant was declared indigent and appointed counsel on direct appeal, Appellant remains indigent and cannot afford paper,pens aand postage to file multiple copies and addition does not have access to copy machines confined in TDCJ-ID. WHEREFORE, Appellant prays this Court grant this Motion and suspend Rule 9.3(b). TEX.R. APP.P. Respectfully submitted, Walter Louis Jackson, Jr. %o$M\ fo&u^ ijathoof)