Tran, Nam Bryan

PD-0377-15 no.OlW\OU \ NAM BRYAN TRAN § IN THE COURT OF § V. § CRIMINAL APPEALS fjlCf) i»i § THE STATE OF TEXAS § OF TEXAS "'"""'" 0P CRIMINAL APPEALS OF TEXAS API? 02 2015 PRO SE MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW _ L ,. *„« . •w Acosta, Clerk TO THE HONORABLE COURT OF CRIMINAL APPEALS: COMES NOW the Petitioner in the above styled and numbered cause and respectfully moves this Honorable Court to extend the time for filing the Appellant's Petition for Discretionary Review in this cause and in support thereof would show to the Court the following: 1. The style and number of this case in the Court of Appeals/ is NAM BRYAN TRAN V. THE STATE OF TEXAS, Appeal No.06-13-00087-CR. 2. The style and number of the case in the trial court is: THE STATE OF TEXAS V. NAM BRYAN TRAN; Cause No.l277354D from the 371st District Court Tarrant/ County/ Texas. 3. The conviction was affirmed in the Court of Appeals on March 4/ 2014. 4. The Texas Court of Criminal Appeals granted petitioner an out-of-time PDR on March 18, 2015. 5. The deadline for filing the Appellant's Petition for Discretionary Review in this cause is 4-17-2015. 6. An extension of time for a period of sixty(60) days is requested that would make the due date 6-16-201! SMRSOW 7. No prior request for an extension of time has been made. 8. The facts relied upon to show good cause for the re quested extension are/ as follows: The Petitioner was represented by court appointed counsel during the appeal of this case to the Court of Appeals. After the conviction was affirmed/ appointed counsel rendered ineffective assistance resulting in this out- of-time PDR. Therefore/ additional time is needed for the Petitioner to either prepare and file the Petion pro se or to seek legal assistance in filing the Petition. WHEREFORE/ PREMISES CONSIDERED/ the Petitioner respectfully requests that the Honorable Court extend time for Filing the Petition For Discretionary Review in this Cause to 6-16-2015. 5""w" """• Nam BrJyan Trah# Telford Unit 3899 State Hwy 98 New Boston, Tx 75570 CERTIFICATE OF SERVICE The Petitioner hereby certifies that a copy of the foregoing Motion was mailed postage prepaid to the Tarrant County District Attorneys Office/ Tim Curry Criminal Justice Center/ 401 W. Belknap, Fort Worth, Tx 76196-0201 on this_ day of March, 2015. NAM BRYAN TRAN PD-0377-15 NAM BRYAN TRAN § IN THE COURT OF § V. § CRIMINAL APPEA&Sj § THE STATE OF TEXAS § OF TEXAS •cowroFoiSJragu PRO SE MOTION REQUESTING LEAVE TO FILE APR 02 2015 AN ORIGINAL COPY ONLY OF THE PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE COURT OF CRIMINAL APPEALS OF TEXAS: Abel Acosta, Clerk COMES NOW the Petitioner in the above-styled and numbered cause and respectfully moves this Honorable Court to grant FILED IN leave to file an original copy only of the Petitj^flp SIGNAL APPEALS cretionary Review and in support thereof would show to the, „„^ Court the following: 1. The style and appeal-, 'number u 4-u Court in the „ * of* Appeals AAbei Acosia, is':Clerk NAM BRYAN TRAN V. THE STATE OF TEXAS, Appeal No.06-13-00087-CR. 2. The petitioner moves that, pursuant to Rule 2, Texas Rules of Appellate Procedure, this Court suspend Rule 9.3(b)/ T.R.A.P./ that requires the filing of eleven(ll) copies of the Petition for Discretionary Review with the Court. 3. The facts relied upon to show good cause for this re quest are/ as follows: The Appellant is indigent and incarcerated and does not have access to a photo copier. The Appellant is presently not represented by counsel and intends to file a Pro Se Petition for Discretionary Review. WHEREFORE/ PREMISES CONSIDERED/ the Petitioner respectfully requests that this Honorable Court grant leave to file an original copy only of the Petition for Discretionary Review with the Court. Respectfully submitted/ Nam Bryan Trant Telford Unit 3899 State Hwy 98 New Boston, Tx 75570 CERTIFICATE OF SERVICE The petitioner hereby certifies that a copy of the foregoing Motion has been mailed postage prepaid to The Tarrant County District Attorney, Tim Curry Justice Center, 401 W. Belknap, Fort Worth/ Tx 76196-0201/ on this day of maWch, 2015. NA v- YAN TRAN