PD-1430_1439-15 RECEIVED..*
C0URT0FCRI1IAL APPEALS
in the NOV 09 2015
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Abel Acosta, Clerk
§ '
William Arthur Mcintosh, § PDR Case No's
Petitioner §
§ Appeal No. 10-15-00328-CR
vs. § thru 10-15-00337-CR
§
THE STATE OF TEXAS, § Trial Court No. 20084 - Cr
Respondent § thru 203p^£gR^
PETITIONER'S MOTION FOR EXTENSION OF TIME TO fififflT OF CRIMINAL APPEALS
PETITION FOR DISCRETIONARY REVIEW
im oqiZq
TO THE MOST HONORABLE COURT OF CRIMINAL APPEALS:
— Abel Acosta, Clerk
COMES NOW, William Arthur Mcintosh, "Petitioner", Pro se and respectfully
files this his Motion for Extension of Time to File Petition for Discretionary
Review ("PDR"), Pursuant to TEX. R. APP. PROC. 68.2(c) and would further
show this most honorable court the following:
I.
The Petitioner's PDR is due in this court on or before October 30, 2015.
II.
The Petitioner needs a Sixty (60) day extension of time to finish his
PDR, then get it copied and mailed into this court.
III.
The Tenth District Court of Appeals Denied Petitioner's Appeal of his
Motion for Appointment of Counsel under the Texas Fair Defense Act and Artile
1.051 V.A.C.C.P., MEMORANDUM OPINION dated October 15,
2015. Petitioner is an incarcerated indivdual and is allowed about two hours
a day in the unit law library. With this being the case it takes a little
longer to get the neccesary research completed. After which Petitioner has
to mail out the original and get copies made and sent to this court. At this
time Petitioner feels that a Sixty day Extension of time would work well
to complete and file his PDR.
IV.
This is the Petitioners first request for an extension of time to file
his PDR. He files this Motion in good faith, not to cause any undue delays,
nor to harass the Respondent.
V.
WHERERFORE, PREMISES CONSIDERED, the Petitioner respectfully prays this
most Honorable Court would GRANT this Motion, extending the deadline to
file PDR by Sixty (60) days.
VI.
I, William Arthur Mcintosh, TDCJ-ID no. 688254, being presently illegally
incercerated under an uncontroverted, illegal null and void judgement of
conviction adn sentence - in the Freeh M. Robertson Unit of the TDCJ-CID
system, in Jones County, Texas do hereby verify and declare under penalty
of perjury that the foregoing Motion and STATEMNTS made herein are all true
and correct.
REspectfully Submitted,
William A. Mclntodsh
Petitioner, Pro se
TDCJ-ID no. 688254
Robertson Unit
12071 F.M. 3522
Abilene, Texas 79601
VII.
I here by certify that a true and correct copy has been sent to the
District Attorney of ellis county , Texas via First Class mail at 109 Sout
Jackson, Waxahachie, Texas 75165
William Mcintosh
William Arthur Mcintosh
TDCJ-ID no. 688254
Robertson Unit
12071 F.M. 3522
Abilene, Texas 79601
Honorable Abel Acosta
Clerk
Court of tCriminal Appeals
201 West 14th Street, Room 106
P.O. Box a2308
Austin, Texas 78711-2308
October 27, 2015
Dear Clerk,
Please find enclosed for filing my Pro Se Motion for extension of time
to file PDR. Also, I filed a declaration fo inability to pay costs on March
22, 2015 on a different pleadings and my situation has not changed so I should
be still indigent. If I need to file another Declaration of inability to
pay costs please let me know and I shall do so.
Sincerely,
William A. Mcintosh