Thomas, Joshua Jerrod

PD-1323-15 CAUSE NO. JOSHUA JERROD THOMAS, § IN THE TEXAS Appellant § ... § V. § COURT OF CRIMINAL APPEALS '§ THE STATE OF TEXAS, § Appellees § AUSTIN , TEMgQgygjQ ||U FILED IN C0URT0FCRMNAl APP-.v? COURT OFCRIMINAL APPEALfR0M THE court of appeals for the ninth district CAUSE NO. 09-14-00220-CR OCT 08 2015 OCT 08 2015 MOTION REQUESTING EXTENTION OF TIME TO FILE AH 1A m . . PETITION FOR DISCRETIONARY REVIEW ADSI ^GOSta., Cleft Abel Acosta, Clerk COMES NOW, Appellant, Joshua Jerrod Thomas, who respectfully requests that this Honorable Court of Criminal Appeals GRANT his request for additional time to file his Petition for Discretionary Review with the Court of Criminal Appeals and would show in support of same the following: Appellant, is an inmate currently confined at the Beto Unit of the TDCJ and was restricted from Direct access to the unit law library for a disciplinary lockdown, and was denied research materials necessary to research and prepare his P.D.R. for this Court. Further the TDCJ law library restricts requests for case law to three cases per day and contains no current case law after 2009 that is readily available, nor case law prior to 1990. The legal materials necessary to prepare a PDR cannot and.will not be available to Appellant until he completes his requests over the next four weeks. - The TDCJ unit law library.does not contain any examples of the format which Appellant needs to follow so as to comply with TRAP 68.4 nor will the Law Library make any copies of Documents to Aid in this courts review pursuant to TRAP 66.4. Appellant is Constrained: to obrtain same from outside of the TDCJ which will require additional-time to do. so. The current Deadline for filing his Petition for Discretionary Review is on or by October 9, 2015. The date .g0i the Court of Appeals Judgement was September 9, 2015, in the above Styled and numbered cause of action. No previous extentions of,time have been sought for filing this Petition for Discretionary Review. >' s ,/? PRAYER / RELIEF REQUESTED WHEREFORE PREMESIS CONSIDERED Appellant Joshua. Jerrod Thomas PRAYS that this Court GRANT him an extention of time of sixty (60) days to file his Petition for Discretionary Review pursuant to TRAP lo.5(b) (1)(3) and require his Petition to be submitted no later than December 8, 2015. „ ,_.-,, , Respectfully submitted, on thistS day of •Sgfe'l ,2015. \s~ ^hua Jerrod Thomas 31104 Beto Unit 1391 FM 3328 Tennessee Colony, Tx. 75880 (903) 928-2217 page 1 of 2 UNSWORN DECLARATION I, Joshua Jerrod Thomas do hereby swear under the penalty of perjury that the herein "Motion Requesting Extention of time to File Petition for Discretionary Review" is being filed not for improper purposes, not to cause delay, and not to inconvenience, harrass, or increase the costs and burdens of this Appeal but in good faith so that justice can be done. Sworn and signed on thisSS day of OgpV ,2015. ' Jdsfiua Jerrod Thomas CERTIFICATE OF SERVICE I, Joshua Jerrod Thomas do certify that I placed a copy of this Motion in a proper wrapper, did affix to same sufficient pre-paid U.S. first class postage, and did address same to the parties listed herein below, and did place same into the available mailing system used for such legal mail. Certified on this ?5 day of SgDV ,2015. *--"•--- Jerrod Thomas 1931104 Beto Unit 1391 FM 3328 Tennessee Colony, Tx.75880 SENT TO: (903) 928-2217 TEXAS COURT OF CRIMINAL APPEALS PO BOX 12308 CAPITOL STATION AUSTIN , TEXAS 78711-2308 AND TO: CAROL ANNE HARLEY , CLERK FOR THE COURT OF APPEALS FOR THE NINTH DISTRICT OF TEXAS 1001 PEARL STREET, 3rd FLOOR BEAUMONT , TEXAS 77701 AND TO: MR. WAYLYN THOMPSON, ASST. DISTRICT ATTORNEY 1001 PEARL ST. BEAUMONT, TEXAS 77701 cc: file page 2 of 2