Justin Wayne Parris v. State

wtytsPW JST",-. •• ;•"•-' " .„,,.;!'{)i WPEA18 FEB S 7 2015 IN TBI emmoPHoi a, nm ^ 720tf Mm 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 'I '^'•'- i •I J 1 o i O o d a o r o h- •2 ui .3 a o a to o o o o er r fO r 3 o si