Heath, Ronnie

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. flftWM?^™^* ffiaurt n£ Appeals Xfe£y Pj^C i^bf-^ 1/ c3 V 3da a^c°g- <£ ^ o- x;. G? a Ci- 1-1 £) cil dp :;.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. ia^o^t o? 3/2i?jij(CaII ?<\ eefonhA cfr nos ** ?fo) SoT&Q off. lUMea^-WGRal UsW tT)vii^ cd l\b\ frw 3/zl|if °aSl: $tiM~ oFsaaae U^uA f> "2"5^W<>4Le.stoneA-lujr\inaft\f fjb J