CAUSE NUMBERS
PD-1600-14
PD-1601-14
PDH602-14
WILLIE EUGENE.HARDEMAN, § IN THE COURT OF
Appellant §
§
VS. § criminal APPEALs'OURTQFCRiiliVAL APPEALS
§
STATE OF TEXAS, § OF TEXAS SEP 17 2015
MOTION for extension of time to Abel Acosta,
®S»iLE EN. BANC-RECONSIDERATION
TO THE HONORABLE JUSTICES OF THE COURT:
FILED IN
Appellant asks the Court to extend the time to file the mQQ.UBTialrCRIMINAL APPEALS
en banc reconsideration.
SEP 17 2C;5
Introduction
Comes Now, Willie Eugene Hardeman, Appellant, Pro se, in the a^fe^e^€pl§, Cierk
and numbered reference Cause, and files this Motion asking the Court to extend
the time to file En Banc Reconsideration.
This motion is filed within the 15 day period to file a motion to extend
the time to file a motion for en banc reconsideration, as required by Texas
Rule of Appellate Procedure 49.8.
B. Argument & Authorities
The Court has the authority under Rule 49.8 to extend the time for a
party to file a motion for en banc reconsideration.
Appellant's Motion for en banc reconsideration is due on 9/10/15.
Appellant requests an additional 30 days to file the motion for en banc
reconsideration, extending the time until 10/10/15.
NO EXTENSION HAS BEEN GRANTED TO EXTEND THE TIME TO FILE THE MOTION FOR
EN BANC RECONSIDERATION.
(1.)
Appellant needs additional time to file the motion for en banc
reconsideration, because; Appellant is an unskilled layman at law. Appellant
has been necessitated to seek unprofessional legal assistance in preparation
and submittal for this legal institument and other semi-legal assistance from
a fellow legal-minded (jailhouse lawyer) inmant.
As the Courts system are well aware, such jailhouse lawyer solicited
unprofessional legal assistance is not always legally and factually sufficient,
oftentimes untimely, and not regularly available. In addition, to obtaining
the Court records for proceedings is exteemely difficult while incarcerated.
The nuances of the law relating to instant causes of action are complex
and beyond the "Legal Ability" of this Appellant. Appellant is unable to
properly act in a semi-knowledgeable Pro se manner as counsel for himself to
present a reasonable and adquate legal instrument.
Appellant has reasoned to believe and does believe that his petition for
discretionary review states a claim upon which relief can be granted. That
Appellant has stated (a) meritorious causes of action and will prevail upon
the judgment of the causes.
C. Conclusion
Appellant's issues complain-in pertinent part-that the "verdict" is so
against the great weight and preponderance of the evidence that it is manifestly
unjustt and not to grant Appellant's herein request for mote time to file en
banc reconsideration would be a miscarriage of justice.
D. Prayer
For these reasons, Appellant asks the Court to grant this motion to
reconsider the case en banc, until 10/10/15.
(2.)
Unsworn Declaration
• My name is Willie Eugene Hardeman, TDCJ #1891985, who is currently
incarcerated at the Jester 3 Unit, located in Fort Bend County, Texas, do
hereby declare that the foregoing facts contained in this motion for the
requested exetension of time are true and correct to the best of my
knowledge, pursuant to the penalty of perjury, as outlined in the Texas
Practice and Remedies Code §132.001, §132.003. So stated on this 10th day of
September, 2015
Willie Eugene Hardeman, #1891985
Declarant
Certificate of Service
I, Willie Eugene Hardeman, certify that a copy of the same has been
mailed first class postage paid, to the Attorney for the State, on this
10th day of September, 2015, addressed to: Attorney General of Texas,
Prosecuting Attorney, P.O. Box 12548, Capitol Station, Austin, Texas 78711.
\a)\)|ttX- \J ei/^yl wrJMflv^
Willie Eugene(jlardeman, #1091935
(3.)