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pn-Odsi'15
PIERCE , JOSEPH MICHAEL, § IN THE TEXAS COURT
(Appellant)
§ OF CRIMINAL APPEALS,
VS,
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§ AUSTIN, TEXAS
COUmxi?CRK;ii;Al"APF"ALS
STATE, OF TEXAS, OCT 29 2015
§
(Appellee)
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1. On IQ" J*/-36J5 "the Texas Court of Criminal Appeals' r9f^!§eG,erk
Appellant's Petition For Discretionary Review, in Cause No'.
ft)-0651-If) •
2. Pursuant to T.R.A.P. Rule 79, Appellant is entitled to pursue
a Motion For Rehearing of the Court's refusal of his Petition
For Discretionary Review.
3. Appellant certifys that, his Motion For Rehearing is based
on substantial intervening circumstances or other significant
circumstances which are specified in the motion, and is made
in good faith, and not for delay purposes.
1.
4. Appellant is proceeding pro se and indigent and has very
limited litigation skills required for preparing and filing
a meaningful Motion For Rehearing.
5. Appellant believes in good faith that his Motion For Rehearing
has substantial merit, thus, requiring to be reviewed in the
interest of justice.
6. Appellant, is not pursuing a Motion For Rehearing to delay
these appellate proceedings, nor to harrass Appellee(s) in any
manner.
WHEREFORE, PREMISES CONSIDERED, Appellant, prays this Court
grant this motion, extending the deadline date for filing
Appellant's Motion For Rehearing to IJ" l3~ pjOlS -providing
an additional (15) days from the original deadline date of
/Q^cx 7 c/U/O , to file his Motion For Rehearing.
Executed on this c* / " day of QCtOq€C , 2015, ,
oseph Michael Pierce
OATH
I, JOSEPH MICHAEL PIERCE, do declare under the penalty of
perjury pursuant to Tex.Civ.Prac.Rem. Code, §132.001 - §132.003,
that the facts stated herein my Motion For Extension of Time
to file a Motion For Rehearing pursuant to T.R.A.P. Rule 79,
is true and correct.
Executed on this C? \ day of (jCj-Qo&P , 2015
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