PD-1679-15 RECEIVED IN
COURT OF CRIMINAL APPEALS
THE TEXAS COURT OF CRIMINAL APPEALS - DEC 23 20f5
marcus Leslie, § AbelAcosta Clerk
Appellant pro se § '
§
US. § COA CASE NO. 06-15-00057-CR
§ RLED ihi
THE STATE OF TEXAS t § COURT OF
CRIMING APPEALS
MOTION FOR EXTENSION OF TIME r"-> o ^,
TO FILE PRO SE '""" c - ^-
PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF SAID COURT:
Ab@l Acosta, Clerk
COMES NOW, Marcus Leslie,. styled hereinafter as "Appellant" pro se and
respectfully files this Motion for Extension of Time in which to file a
Petition for Discretionary Review (PDR), pursuant to Tex.RulesApp.Proc. 68.
On December 3, 2015 the Sixth Court of Appeals rendered its opinion
regarding Appellant's Direct Appeal; to delete the deadly weapon finding from
the trial court's judgment and affirm the judgment, as modified.
For the following reasons, Appellant is requesting an additional 60-days to
prepare his PDR:
1) Appellant's deadline for filing a PDR is January 3, 2015;
2) Appellant has requested no previous extensions of time in this action;
3) Appellant is a pro se litigant and a layman to law and all of its
complicated rules, and should not be held to the exact same time constraints
and standards as a licensed attorney; and
k) inherent delays with the prison law library's next-day shepardizing
and inter-loan system, limited legal resources, and outdated books, add-
tional time is required to receive legal material and cases, research,
compose, and deliver documents to the courts.
Because of these reasons and in order to adequately prepare an effective
and viable PDR worthy of this Court's consideration, Appellant request this
Honorable Court to extend his time to file his PDR.
PRAYER
WHEREFORE PREMISES CONSIDERED, Appellant PRAYS that this Court GRANT
this motion and extend the deadline to file the PDR an additional 60-days.
The applicant presents this motion for no reason of delay other than justice
being served.
[SUBMITTED and SUBSCRIBED on this the £j_ day' of December 2015]
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Respectfully submitted
Appellant pro se TDC3 #2001223
Connally Unit
899 FM 632
Kenedy, Texas 7B119
DECLARATION
"I, Marcus Leslie, TDCO #2001223, presently incarcerated in
The TDCD-CID at the ConnallyUnit in Karnes County, Texas, declare
under penalty of perjury under Chapter 132 of Texas Civil Practices
and Remedies Code and 28 U.S.C. § 1746, that the facts stated in
this motion are true and correct: and that I placed this document
in the prison mailbox on this date."
"Executed on this the fi\ day of December 2015
Marcus Leslie, pro se
CERTIFICATE OF SERVICE
I certify that on this the J$ J day of December 2015, I sent
the following parties a true and correct copy of this motion by
U.S. Mail thru the prison mail system in a postage paid package
to the addresses listed below;
Texas Court of Criminal Appeals
P.O. Box 12308, Capitol Station
Austin, Texas 78711-2308
Attn: Abel Acosta, Court Clerk
District Attorney's Office
601 Main St.
Texarkana, Texas 75501
Attn: Lauren Sutton, Asst.DA
Marcus Leslie, #2001223
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