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FIRST DISTRICT COURT OF A ^ •• 'JWWE
CLERK
AT HOUSTON, TEXAS
JUSTIN WAYNE PARRIS I
I Court of Appeals- No. QX-14-O05O2-CR
V. §
THE STATE OP TEXAS I Trial Ct. Case No. 1352699
AaD&Uee s
APPELLANT'S SECOND MOTION FOR EXTENSION OF TIME
TO PILE APPELLANT'S BRIEF
TO THE HONORABLE JUSTICES OP SAID COURTS
COMBS NOW* JUSTIN WAYNE PARRIS, "Appellant/" Pro Se in the above styled and
numbered cause/ and respectfully files this SECOND MOTION FOR EXTENSION OF TIME TO
FILE APPELLANT'S BRIEF/ requesting an extension of at least thirty (30) days but
preferrably ninety (90) days in which to file his Pro Se response to Appellate
Counsel's Anders' Brief. In support thereof/ Appellant shows the court the follow
ing:
I.
On November 24/ 2014/ Appellant received notice from courts, appointed Appel
late counsel/ stating that he had filed an Anders' Brief on Appellant's behalf.
II.
Appellant's current due date for his pro se response to counsel's Anders*
Brief is February 27/ 2015. Appellant previously requested an extension of time/
which this Court granted on January 13/ 2015/ granting Appellant 45 days from that
date.
III.
Appellant's request for an additional extension of time is based upon the
following facts:
a. Appellant is entitled to review a copy of the record and submit his own pro se
brief in response to counsel's Anders' Brief. Appellant did not receive said
copy of the record until January 23/ 2015/ and has not had sufficient time to
review the record and do the research necessary to prepare a brief in response
Seamd M*kh of Extension of Tims - Appeal Na. O1-14-O0502-CR - Page 1
to counsel's Anders* Brief.
b. Appellant believes that he may be entitled to the appointment of new Counsel
in this matter/ therefore he has filed a notion requesting the appointment of
new counsel; with this Honorable Court/ as well as the District Court.
c. Appellant is a layman of the law and knows very little about the law.
do Appellant is unable to retain counsel/ due to indegency.
o. Appellant's access to the Law Library is limited to about ten (10) hours per
week.
£• Appellant's comprehension level is limited and he must therefore rely on the
assistance of another inmate in order to complete a brief/ as well as these
motions.
g. Appellant believes that the record before him is incomplete/ as it does not
include anything on the Suppression Hearing/ on Appellant's Motion to Suppress
that was filed pre-trial.
WHEREFORE/ PREMISES CONSIDERSDrAppelant prays this Court will grant this
MOTION and extend the deadline for filing a pro 3e brief in response to counsel's
Anders' Brief in Appeal No. 01-14-00502-CR by at least 30 days but preferrably by
90 days/ to provide Appellant with sufficient time to prepare his brief.
1/ JUSTIN WAYNE PARRIS/ TDCJ # 1937601/ being presently incarcerated in the
French M. Robertson unit of the Texas Department of Criminal Justice in Jones cou
nty/ Texas; hereby verify and declare under penalty of perjury that the foregoing
statements are true and correct; as well as offered in good faith.
RESPECTFULLY RESPECTED/
SIGNED AND EXECUTED on this the 20th day of February, 2015.
/a/
Appellant/ Pro Se
Justin Wayne Parris # 1937601
French M. robertson unit
10071 P.M. 3522
Abilene/ Texas 79601
(325) 548-9035
CERTIFICATE OF SERVICE;
The above signer hereby certifies that a true and correct copy of the fore
going MOTION has been served on all parties/ via 1st Class U.S. Mail/ Postage Pre
paid/ dropped in the outgoing prison mailbox on this the 20th day of February/
2015; adressed to:
Seccnd Motion of Extension of Time - Appeal NO. qiH4rG0BO2KR - ™" ——~ — page 2
• Christopher Prine/ Clerk • Alan Curry
First Court of Appeals Assistant District Attorney
301 Fannin street Harris County District Attorney's Office
Houston/ Texas 77002-2066 1201 Franklin/ 6th Floor
Houston/ Texas 77002
JWP/awr-File
[THIS SPACE INTENTIONALLY LEFT BLANK ]
Second Motion of Extension of Tine - Appeal No. QHL4-006Q2-CR - Page 3
JUSTIN WAYNE FARMS # 1937601
French M. Robertson Unit, 12071 ¥M. 3522, Abilene*Texas 79601
February 20, 2015 ._.„. fwd»»
*STCOURT OF APPEALS
Christopher Prine, Clerk Hourrn. rrv,%3
First Court of Appeals _. t
301 Fannin Street hhy *•' 05
Houston, Texas 77002-2066 Christopher a.
RE: APPELLANT'S SECOND MOTION FOR EXTENSION OF TIME TO FII£ APrmiAfi¥^^BIEFjQ£VU
: APPELLANT'S MOTION REQUESTING APPOINTMENT OF NEW COUNSEL
Dear Clerk:
Greetings! I hope this finds you in the best of health and spirits. Please
find enclosed my pro se APPELLANT'S SECOND MOTION FOR EXTENSION OF TIME TO FILE
APPELLANT'S BRIEF and mppro se APPELLANT'S MOTION REQUESTING APPOINTMENT OF NEW
COUNSEL. I ask that you file these motions immediately, and bring them to the
attention of the Court at your earliest convenience.
I further ask that you notify me of any action taken on these motions in a
timely manner.
Lastly, please return a date/time stamped copy of this letter to me at the
address below, so that I (Say file it with my records in this matter.
Your assistance in this very important matter is greatly appreciated.
Respectfully,
/s/
Appellant, Pro Se
Justin Wayne Parris # 1937601
French M. Robertson Unit
12071 F.M. 3522
Abilene, Texas 79601
(325) 548-9035
JWP/ayr-File
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