PD-0330-15
PD-0330-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 3/26/2015 11:49:33 PM
IN THE COURT OF CRIMINAL APPEALS OF Accepted 3/27/2015 11:24:45 AM
TEXAS
ABEL ACOSTA
CLERK
JAY SANDON COOPER, §
§
Appellant, §
§
v. §
March 27, 2015
§ CASE NO. __________________________
THE STATE OF TEXAS §
§
Appellee. §
APPELLANT’S MOTION TO EXTEND THE TIME TO FILE
APPELLANT’S PETITION FOR REVIEW
Appellant Jay Sandon Cooper (“Appellant”), under the authority of TRAP Rules 10.1(a),
10.5(b), and 68.2, requests this Court to extend the time to file Appellant’s Petition for Review.
I. REQUIRED CONTENTS
(A) Appellant’s Petition for Review was due on March 11, 2015. [TRAP Rule 53.7(a)] This
Motion for Extension is filed within 15 days after the due date. [TRAP Rule 53.7(f)]
(B) Appellant seeks an extension of time of 21 days (6 days from today) to Wednesday, April
1, to accept and file Appellant’s Petition for Review. [TRAP Rule 10.5(b)]
(C) Trial Court: The State of Texas v. Jay Sandon Cooper, Cause No. 2011-2-1391, in the
County Court at Law No.2, Grayson County, Texas.
(D) Appeal therefrom was to the Fifth Court of Appeals at Dallas, Texas, Case No. 05-14-
00089-CR, Jay Sandon Cooper, Appellant v. The State of Texas, Appellee. Cooper v. State, No. 05-
14-00089-CR, 2015 WL 150081 (Tex. App. Jan. 8, 2015)
(E) The Trial Court judgment was signed on January 23, 2014. A Motion for New Trial was
fled in the Trial Court on February 24, 2014. The Trial Judge recused herself after trial. The Motion
for New Trial was overruled by operation of law (Rule 329b(c), Tex.R.Civ.P.) on May 12, 2014 (75
days after the judgment was signed). Notice of Appeal was filed on January 24, 2014. The Fifth
APPELLANT’S MOTION FOR EXTENSION Page 1
Court of Appeals’ Opinion was signed on January 8, 2015. Mr. Cooper filed a Motion for Rehearing
on January 23, 2015, that was denied on February 9, 2015.
(F) The facts relied upon to support this request are set forth below in Paragraph II.
(G) There have been no previous extensions requested by and granted to Appellant regarding
this matter.
II. FACTS IN SUPPORT OF MOTION
Mr. Cooper and his spouse are challenging the unlawful sale of their homestead (Case No.
3:14-cv-02795-N-BF, U.S. Northern District of Texas), and recently their time and resources have
been directed to that case and the approaching trial regarding the death of Mr. Cooper’s father. Case
No. 1:11-cv-1934, U.S. Western District of Louisiana. This request is not made solely for purposes
of delay, but so that substantial justice may be done. Mr. Cooper represents himself and has no
relief.
III. ARGUMENT AND AUTHORITIES
In accordance with TRAP Rule 68.2, Appellant has submitted his Motion for Extension in
accordance with Rule 10.5(b) no later than 15 days after the last date for filing a petition for review.
IV. PRAYER
For the above reasons, Appellant asks the Court to grant an extension of time to April 1,
2015, to file his Petition for Review.
Respectfully submitted,
By: /“s”/ Jay Sandon Cooper
JAY SANDON COOPER, Pro Se
1520 Janwood Dr.
Plano, Texas 75075
(972) 358-8999
No Fax
JaySandonCooper@gmail.com
APPELLANT
APPELLANT’S MOTION FOR EXTENSION Page 2
CERTIFICATE OF CONFERENCE
In accordance with TRAP Rule 10.1, this is to certify that movant attempted to confer with
counsel for Appellee by telephone on March 11, 2015, concerning this Motion to Extend the Time to
File Appellant’s Petition for Review. Counsel was not available, so a voice mail message was left.
No opposition has been received since.
By: /“s”/ Jay Sandon Cooper
JAY SANDON COOPER, Pro Se
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of the foregoing instrument was
served by United States Mail on March 26, 2015, upon:
Joe D. Brown
Karla Renae Baugh-Hackett
Grayson County District Attorney
Grayson County Justice Center
200 S. Crockett St.
Sherman, Texas 75090
By: /“s”/ Jay Sandon Cooper
JAY SANDON COOPER, Pro Se
APPELLANT’S MOTION FOR EXTENSION Page 3