Piland, James Earl v. State

PD-0076-15 COURT OFCRIMINAL APPEALS Cause No. MAY 15 2015 IN THE TEXAS COURT OF CRIMINAL APPEALS Abel Acosta, Clerk TRIAL No. CR-13-214 FILED IN COURT OF CRIMINAL APPEALS JAMES EARL PILAND § IN THE 4th Petitioner § MAY 15 2015 v. JUDICIAL DISTRICT COURT Abel Acosta, Clerk THE STATE OF TEXAS OF RUSK COUNTY/ TEXAS Respondent PRO-SE MOTION REQUESTING LEAVE TO FILE AN ORIGINAL COPY ONLY OF THE PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE JUDGE(S) OF:SAID COURT; COMES NOW, James Earl Piland/ Petitioner, pro-se in the above styled' and numbered cause/ and' respectfully moves this Honorable Court to grant leave to file an original copy only of the Petitioner's Petition For Discretionary Review. The Petitioner would'show the following in support: 1. The style and appeal number in the Sixth Court of Appeals is: JAMES EARL PILAND vs. THE "STATE OF TEXAS, Appeal No. 06-14-00063-CR. 2. The Petitioner moves that, pursuant to Rule 2, Rules of Appellate Proce dure, this Court could suspend Rule 9.3(b) T.R.A.P., which requires the filing of eleven (11) copies of the Petition For Discretionary Review with this Court. 3. The facts relied upon to show good cause for this request is that the Petitioner is indigent, is incarcerated, is not permitted to earn or handle money, does not have access to a copy machine, and is unable to obtain a loan due to inability to reimburse it. WHEREFORE, ALL PREMISES CONSIDERED, the Petitioner respectfully requests -1- this Honorable Court grant leave for the Petitioner to file, an original copy only of the Petition For Discretionary Review with the Court. Respectfully Submitted, Piland, TDCJ-CID #1919190 Mac Stringfellow Unit 1200 F.M. 655 Rosharon, Texas 77583 CERTIFICATE OF SERVICE The Petitioner certifies that a true and correct copy of the above Motion has been served by placing copies of the:same, first class mail, postage prepaid, addressed to the following: STATE PROSECUTING "ATTORNEY P.O. Box 12405, CAPITOL.STATION AUSTIN, TEXAS 78711 AND TO RUSK COUNTY ATTORNEY COURTHOUSE 115 MAIN STREET, ROOM 302 HENDERSON, TEXAS 75652 EXECUTED on this the , 2015. es Piland, TDCJ-CID #1919190 PETITIONER, PRO-SE -£-