PD-0953-15
CASE No. 09-13-00459-CR
TRIAL No. 13-03-03256-CR
fo)[Sf^cn,7re(ni
u \*c=a ^=y Lb-a l' xy (!=, i±-t&
COURT OF CR»!ALAPPFALS
IN THE TEXAS COURT
JUL 27 2015
OF
CRIMINAL APPEALS im?H
AUSTIN, TEXAS
MOTION FOR EXTENSION OF TIME TO FILE
PETITION FOR DISCRETIONARY REVIEW
LONNIE J. JONES Jr. FILED IN
COURT OF CRIMINAL APPEALS
(PETITIONER)
vs .
JUL 27 2015
THE STATE OF TEXAS Abel Acosta, Cierk
(APPELLEE)
LCNNIE J. JONES Jr.
TDCJ # 1889803
(PRO SE)
CASE No. 09-13-00459-CR
TRIAL No. 13-03-03256-CR
LONNIE JAMES LONES Jr § IN THE TEXAS COURT
§
§ OF
vs. §
§ CRIMINAL APPEALS
§
THE STATE OF TEXAS § AUSTIN, TEXAS
MOTION FOR EXTENSION OF TIME TO FILE
PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES, LONNIE JAMES JONES J r . , APPELLANT-PETITIONER IN THE ABOVE
STYLED AND NUMBERED CAUSE, MOVES THIS COURT TO GRANT AN EXTENSION OF TIME
TO FILE A PETITION FOR DISCRETIONARY REVIEW, PURSUANT TO RULE 68.2(c) OF
THE' TEXAS RULES OF APPELLATE PROCEDURE, AND FOR GOOD CAUSE SHOWS THE FOLLOW
ING:
1.) THIS CASE WAS ON APPEAL IN THE COURT OF APPEALS FOR THE NINTH (9th)
DISTRICT.
2.) THE JUDGEMENT WAS MADE ON JUNE 24, 2015.
3.) THE CASE WAS STYLED LONNIE JAMES JONES Jr. vs. THE STATE OF TEXAS,
CASE No. 09-13-00459-CR.
4.) NO MOTION FOR REHEARING -or- EN BANC CONSIDERATION WAS FILED IN THIS
CASE.
5.) PETITIONER REQUEST THE COURT TO GRANT A SIXTY (60) DAY TIME EXTENSION.
6.) PETITIONER HAS LIMITED ACCESS TO COURTS, (LAW LIBRARY TIME), DUE
TO OVER CROWDED FACILITY, ON-OFF ROLLING SECURITY LOCKDOWNS.
7.) PETITIONER IS A PRO SE LITIGANT WITH LIMITED LAW SKILLS, HAVING TO
RELY ON DIALATORY - ELECTRONIC ACCESS TO UPDATE CASE LAW - MATERIALS
NEEDED AND SHOULD NOT BE HELD TO THE STRINGENT STANDARDS OF A LICENSED
ATTORNEY.
- 1 -
8.) THIS CASE WAS ORIGINALLY A THIRD (3rd) DEGREE FELONY ENHANCED TO
FIRST (1st) DEGREE, (5 - 99), PUNISHMENT - WHERE PETITIONER SUFFERED
FORTY (40) YEAR T.D.C J.-C.I .D. CONFINEMENT.
9.) PETITIONER IS CURRENTLY INCARCERATED.
10.) PETITIONER, TO DATE, IS DILIGENTLY EXAMINING THE APPELLANT BRIEF
AND ALL LOWER COURT PROCEEDINGS AND REQUIRES ADDITIONAL TIME TO SUFF
ICIENTLY ANALYZE MATERIAL CONTAINED THEREIN IN ORDER TO EFFECTIVELY
PREPARE A MEANINGFUL PETITION IN THIS CASE.
11.) PETITIONER HAS A DOCUMENTED HISTORY OF MENTAL HEALTH ILLNESS AND
TO DATE SUFFERS FROM SUCH - ESSENTIALLY REQUIRES EXTRA TIME TO PERFECT
A PETITION FOR DISCRETIONARY REVIEW.
12.) PETITIONER'S DISCRETIONARY REVIEW IS PRESENTLY DUE ON JULY 24, 2015.
13.) PETITIONER RESPECTFULLY REQUEST AN EXTENSION OF TIME TO FILE HIS
PETITION FOR DISCRETIONARY REVIEW OF SIXTY (60) DAYS FROM THE PRESENT
DUE DATE OF JULY 24, 2015.
WHEREFORE PREMISES CONSIDERED, PETITIONER PRAYS THAT THE COURT GRANTS
THIS MOTION FOR EXTENSION OF TIME TO FILE A PETITION FOR DISCRETIONARY REVIEW,
AND FOR SUCH OTHER -and/or- FURTHER RELIEF/'AS THE COURT DEEM APPROPRIATE.
RESPECTFULLY SUBMITTED,
LONNIE JAMESJONES Jr.
TDCJ # 1889803
H.H. COFFIELD UNIT
2661 FM 2054
TENNESSEE COLONY, TEXAS
75884-5000
- 2 -
CERTIFICATE OF SERVICE
I, LONNIE JAMES JONES Jr., TDCJ # 1889803, PRESENTLY
CONFINED IN THE TEXAS DEPARTMENT OF CRIMINAL JUSTICE - C.I.D.
AT THE H.H. COFFIELD UNIT IN ANDERSON COUNTY, DECLARE UNDER
THE PENALTY OF PERJURY AND CERTIFY THAT A TRUE AND CORRECT COPY
(TOTALING 3 pages) OF THE ENCLOSED INSTRUMENT, MOTION FOR EXTEN
SION OF TIME, WAS PLACED IN THE PRISON LEGAL MAILING SYSTEM
ON JULY 23, 2015, TO FORWARD via U.S.P.S. FIRST CLASS POSTAGE
TO: TEXAS COURT OF CRIMINAL APPEALS, ATTN: "ABEL ACOSTA" (CLERK),
P.O. BOX 12308, CAPITOL STATION, AUSTIN, TEXAS 78711-2308.
LONNIE JAWK JONES Jr.
TDCJ # 1889803
H.H. COFFIELD UNIT
2661 FM 2054 '''
TENNESSEE COLONY, TEXAS
75884-5000
UNSWORN DECLARATION
I, LONNIE JAMES JONES Jr., AM THE PETITIONER AND BEING
PRESENTLY INCARCERATED IN THE TEXAS DEPARTMENT OF CRIMINAL JUST
ICE - C.I.D., DECLARE UNDER PENALTY OF PERJURY THAT, ACCORDING
TO MY BELIEF, THE FACTS STATED IN THE ABOVE AND FOREGOING ARE
TRUE AND CORRECT.
SIGNED ON JULY 23, 2015. , , __ .
LONNIE JAMES JONES Jr.
TDCJ # 1889803
(PRO SE)