PDR NO.
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EDWARD FLORES, COURT OF CRIMINAL APPE&S IN THE COURT OF CRIMINAL
APPELLANT, § r-,~~
OCT 0o2015 § appeals at Austin ,,JfEx£s?IVED m
Vs. § '--WiFORfilM APPEALS
§
the state of texas ,Abel Acosta, Clerk § QQJ 02 2015
Pi.L L £j 1_j J_iHiIII • ^5
AEPEELANT'S MOTION FOR AN EXTENTION OF TIME TO FILEVAs'i ArtftRta njgpfr
MOTION FOR REHEARING
COMES NOW, Edward Flor.es, TDCJ #01848741, Appellant in the
above -styled and -number and files his motion to seek for an
extention of time to file a motion for rehearing pursuant to Rule
>79y of the Texas Rules of Appellate Procedure, and shows this
Honorable Court GOOD CAUSE to GRANT this motion as follows:
1* The Appellate is current incercerated in the TDCJ-CID
Coffield unit in Anderson County, and is indigent.
2* On September 22, 2015, Scott Pawgan sent a letter corres-
pondance (by certified mail #7014 3490 0002 3263 3160) advising
the Appellant that his Petition for Discretionary Review (PDR)
was"" denied on September 16, 2015.
3*v'Scott Pawgan did not send him his motion for rehearing
that was overruled in the court of appeals, nor did Pawgan send
the Appellant's PDR to him. In other words, the Appellant does
not have the necessary documents to properly•prepare for a motion
for rehearing within this Honorable Court.
4* The Appellant sent a letter correspondance to Scott Pawgan
to ask for him to send all the above documents, including this
Honorable Court's postcard dening the PDR.
1
5*0Normally the Appellant would only seek for a 30 day
extention, however, considering that the Appellant is now without
counsel for his help and does not have any of the vital documents
to properly prepare for his motion for rehearing, the Appellant
is respectfully seeking either a 45 or 60 day extention, unless
this Honorable Court provides the Appellant with the necessary
documents.
6«.The current deadline for filing a Motion for rehearing :
falls on October 1, 2015.
7* The Appellant's proposed deadlines would either fall on
November 16, 2015, or Noevember 31, 2015, or a reasonable amount
of time deem fit in this Honorable Court's eyes.
PRAYER FOR RELIEF
Appellant prays that this ^Honorable Court will GRANT this
motion and extend the deadline for filing to: (1) November 16,
2015; (2) November 31, 2015; or (3) a reasonable amount of time
to properly retrieve his documents from either this Honorable >
Court or from his previous counsel.
* Edward Flores
#01848741-Coffield
2661 EM 2054
Tenn.colony, Tx. 75884
Pro se.
INMATE DECLARATION
I, Edward Flores, TDCJ #01848741, currently incarcerated in
the TDCJ-CID Coffield unit in Anderson County, Texas, declares
that the foregoing is true and correct under the penalty of per-
2
•H
jury.' Executed this day of September 26, 2015.
K^^ __^_
Edward Flores
#01848741-Coffield
2661 FM 2054
Tenn.Colony, Tx. 75884
Pro se.
PROOF OF MAILING
I, Edward Flores, TDCJ #01848741, have placed this motion for
an extention of time to file his motion for rehearing, into the
internal mailing system of the Coffield unit in Anderson County
on September 26, 2015. This is true and correct under the penalty
of perjury. Executed this day of September 26, 2015.
Edward Fl
#01848741-Coffield
2661 FM 2054
Tenn.Colony, Tx. 75884
Pro se.
CERTIFICATE OF GOOD FAITH
This motion is done in good faith and not for delay. All
Appellant's motives are well placed and only seeks for a pro
per and adequate opportunity to file his motion for rehearing.
This is true and correct under the penalty of perjury. Executed
this day of September 26, 2015.
Edward Flores
#01848741-Coffield
2661 FM 2054
Tenn.Colony, Tx. 75884
Pro se.
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