PD-1107&1108-15
N0.__:
IN THE
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
JAMES KEELS JR. RECEIVED IN
COURT OFCRJWIINAL APPEAlB
V.
AUG 24 2015
THE STATE OF TEXAS
PROM APPEAL NO: 10-14-00140-CR & 10-14-00141-CR FILED IN
TENTH COURT OF APPEALS AT WACO COURT OF CRIMINAL APPEALS
TRIAL COURT CASE NO: C-34828-CR & C-34855-CR AUG 27 2015
COUNTY COURT OF LAW AT NAVARRO COUNTY, TEXAS
Abel Acosta, Clerk
FIRST MOTION FOR EXTENSION OF TIME TO FILE
PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUSTICES OF THE COURT OF CRIMINAL APPEALS:
COMES NOW, JAMES KEELS JR., Petitioner pro se, and files this
Motion for an extension of sixty (60) days in which to file a
Petition for Discretionary Review. In support of this Motion,
Petitioner shows the Court the following:
I .
Petitioner was convicted of two charges: 1) Possession of
a controlled substance in the amount of 4 grams or more but less
than 200 grams, and 2) tampering with physical evidence,in the
above numbered cause numbers, styled James Keels Jr. vs. The
State of Texas. The Petitioner appealed to the Tenth Court of
Appeals at Waco. The case was affirmed on July 30, 2015.
II.
The present deadline for filing the Petition for Discretionary
Review is August.29, 2015. Petitioner has not requested extensions
prior to this request.
III.
Petitioner's request for extension is based upon the following
facts: Petitioner was not informed of the Court of Appeals decision
affirming his case until August 14, 2015. Petitioner is currently
unable to afford legal assistance in filing his Petition and needs
an additional sixty days to properly research the prison law
library in order to meet the procedural requirements.
WHEREFORE PREMISIS CONSIDERED, Petitioner prays this Court
Grant this-Motion and extend the deadline "for filing the Petition
for Discretionary Review in Case No. 10-14-00140-CR & 10-14-00141-
CR to October 28, 2015.
Janiep Keels Jr., Pro se
CERTIFICATE OF SERVICE
I certify that a carbon copy of this Motion was mailed to
R. Lowell Thompson Criminal District Attorney at 300 W. 3rd Ave.,
Suite 203, Corsicana, TX 75110 on August 19, 2015.
Jam] Keels vJr. ,[ Pro se
INMATE DECLARATIO
•I, James Keels Jr. TDCJ#1920712, being presently incarcerated
in the Huntsville Unit of TDCJ-CID in Walker County, Texas, verify
and.declare under penalty of perjury that the.foregoing statements
are true and correct. Executed on August 19, 2015.
J^mesl Keels Jr.V Pro se