Luna, Jesus Marcial Jr.

PD-0618-15 PDR NO, JESUS MARCIAL LUNA JUNIOR, § Appellant, § IN THE COURT OF CRIMINAL § v. § APPEALS AT AUSTIN, JTEXAS-. § RfcCfc THE STATE OF TEXAS, § COURT OF CRIMINAL APPEALS Appellee. § MAY 22 2015 MOTION FOR AN EXTENTION OF TIME TO FILE A PETITION FOR DISCRETIONARY REVIEW Abel Acosta, Cler^ COMES NOW, Jesus Marcial Luna Junior, Appellant in the above styled and numbered cause, and files his motion for an extention of time pursuant to rule 68.2(c) of the Texas Rules of Appellate Procedure, and shows this Honorable Court GOOD CAUSE to GRANT this motion as follows: 1* The Appellant was affirmed on April 29, 2015, by the Eighth District Court of Appeals at El Paso. See Jesus COURT OF CRIMINAL APPEALS Luna Junior v. State, No. 08-13-00084-CR (Tex.App.--E1 Paso, 04- MAY 22 2015 29-15). 2' There has been no motion for rehearing filed AteSl^COSlSic^lerk reconsideration filed, that the Appellant knows of. Additionally, there has no other extention of time filed within this Honorable Court. 3- The Appellant is seeking for a 60 day extention in order for the Appellant to properly file his Petition in a proper man ner. The due date is currently on May 29, 2015. The 60 day ex tention will set the proposed date to July 28, 2015. 4* The Appellant is currently without counsel for his help, and is proceeding in the pro se status. 5* Being a layman in the law, the Coffield 'Unit's law lib- page 1 rary only allows for offenders to have 10-15 hours per week to conduct their research, properly prepare for filing, and reply to any court documnets required. 6* The Appellant believes that he can meet the deadline on July 28, 2015, in order for this Court to review in a timely man ner . PRAYER The Appellant prays that this Honorable Court will GRANT this motion and reset the due.date to July 28, 2015. or in the alter native, reset the current due date to a reasonable time frame in order for the Appellant to properly file his Petition on his own behalf. INMATE DECLARATION I, Jesus M. Luna Junior, #1883000, being currently incarcer ated in the TDCJ-CID Coffield Unit in Anderson County, Texas, declares that the foregoing is true and correct under the penalty of perjury. EXECUTED THIS DAY OF MAY 19, 2015. •7U SUS M. #01883000- 2661 FM 2054 Tenn.Colony, Tx. 75884 PROOF OF MAILING I, Jesus M. Luna Junior, #01883000, declares under the penalty of perjury that I have placed this motion, in the internal mail box of the Coffield unit in Anderson County, Texas on May 19, 2015. ^SUS M. LUi '#01883000-Coff: 2661 FM 2054 Tenn.Colony, Tx. 75884 pro se. page 2 of 2