PD-1206-15
No.
Ronnie Heath § In the Texas Court of
vs. § Criminal Appeals
The State of Texas § at Austin, Texas
•On Appeal from the Fifth Court of Appeals COURTOFOR^
inCauseNo.05-14-00806-CR §gp If f|f|
Appellant's Motion to Extend the rmiRTncl ^
Time for Filing a Petition for Discretionary Review ' 0F CRIM,NAL APPEALS
SEP 17 2015
To the HonorableJudges of said Court: Abel Acosta, Clerk
Comes now Appellant, and respectfully requests, that the time for filing a
Petition for Discretionary Review in the above-styled and numbered cause be
extended. In support of this motion Appellant would show:
1. Gn July 30, 2015, Appellant's conviction was affirmed by the Fifth Court
ofAppeals inCause No. 05-14-00806-CR styled Ronnie Heath v. The State ofTexas.
2. On August 5, 2015, Appellant's counsel filed a Motion for Rehearing.
3.' On August 26,2015, Appellant's Motion for Rehearing was granted and the
Court issues ah Opinion on Rehearing affirming the conviction.
4. The present deadline for filing a Petition for Discretionary Review is
September 25, 2015. Appellant respectfully requests an extension of time until
November 24, 2015.
5. No previous extension of time has been granted.
6. Appellant would show the Court that a reasonable explanation exists for the
requested extension. Appellant is currently incarcerated in the Texas Department of
Criminal Justice and has limited legal knowledge. Appellant must go to the unit law
library to research and draft the issues.
Wherefore, premises considered, Appellant respectfully requests that the time
for filing a Petition for Discretionary Review be extended to November 24, 2015.
? Respectfully submitted,
Ronnie Heath, Appellant # 14018945
Kays Tower 03-E
P.O. Box 660334
Dallas, TX 75266-0334
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing motion has been served on the
Dallas County District Attorney's Office, Appellate Division, 133 N. Riverfront
Blvd., LB 19, Dallas, Texas, 75207, Jjy-ttep^siting same in the United States Mail,
Postage Prepaid on ^.Dt , 7 . 20]
Ronnie Heath, Appellant
Affirmed as Modified and Opinion Filed July 30, 2015.
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:;.n Saturday, y !, 2014 AT A.BOUY 8:50 FM. A TKEFT/AEUMINUIvi OFFENSE OCCURRED /
,AS COUNTY, TEXAS. THE COMPLAINANT EN THIS OFFENSE IS ACTION
n}} w i l l be he -'KbbJilN ED BY BORIS GRIN STEIN. THE STOLEN' AND RECOVERED PROPERTY i'KI S
OFFENSE IS ALUMINUM METAE($ 166.50). TEE PR OPF WAS R U V j-HA ,.T THE LOCATION
RELEASED TO THE COMPLAINANT.
ON SATURDAY, MARCH 29, 2014 AT ABOUT 8:50 PM; WITNESS EUAN GUERRA WAS WORKING SECURITY AT
THE COMPLAINANTS CLOSED BUSINESS. WITNESS GUERRA. OBSERVED SUSPECT RONNIE HEATH INSIDE
THE FENCED STORAGE YARD OF THE COMPLAINANTS BUSINESS. THE SUSPECT WAS THROWING PIECES OF
ALUMINUM OVER THE FENCE ONTO THE SIDEWALK OUTSIDE THE COMPLAINANT'S BUSINESS. WITNESS
GUERRA CONTINUED TO WATCH THE SUSPECT WILE CALLING 9-1-1. THE SUSPECT THEN USED A LADDER
TO CLIMB BACK OVER THE COMPLAINANT'S FENCE AND DROPPED DOWN TO THE SIDEWALK. WITNESS
GUERRA OBSERVED THE SUSPECT PUTTING THE STOLEN METAL INTO A. SHOPPING CART OUT ON THE
SIDEWALK. UNIFORMED DALLAS POLICE OFFICERS TROY KLINGLESMITH #6415 AND LASHARON WATSON
#9311, ALONG WI'FH THE POLICE HELICOPTER, RESPONDED TO THE LOCATION. OFFICERS LOCATED HIE
SUSPECT WALKING ON TEE SIDEWALK OUTSIDE OF THE COMPLAINANTS BUSINESS. THE SUSPECT WAS
PUSHING A SHOPPING CART CONTAINING THE STOLEN METAL. OFFICERS TOOK THE SUSPECT INTO
CUSTODY.' WITNESS GUERRA: IDENTIFIED AND TOOK. POSSESSION Or THE STOLEN ALUMENUM. WITNESS
TiR" TO FEW STER.RETT. "
Ail :> i, ,: WAS ASSIGNED
rECTiV'- R S?OK T3I>.' 3Y TELEPHONE. V
'•')' All "i.\ J.;
'WITNESS GRINSTEIN
STORaGI jj VISED THAT TNI
COMPLAINANT DOES WISH TO PROSECUTE THE SUSPECT.
A CRIMINAL HISTORY CHECK OF THE SUSPECT REVEALED TWO PRIOR FELONY CONVICTIONS. ON 9/7/05, ON
CAUSE # F05-45500, THE SUSPECT WAS CONVICTED OF FORGERY OUT OF THE 292nd JDC. THE SUSPECT WAS
SENTENCED TO 2 YEARS IN PRISON. ON 12/29/11, ON CAUSE # Fl 1-17208, THE SUSPECT WAS CONVICTED OF
THEFT/ENHANCED/2 PRIORS OUT OF THE 363rd JDC. THE SUSPECT WAS SENTENCED TO 45 DAYS IN JAIL.
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