McIntosh, William

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