NO. PD-1616-15
COURT OF CRIMINAL APPEALS RECEIVED IN
COURT OF CRIMINAL APPEALS
RICHARD LARES •
V. DEC 3 0 2015
THE STATE OF TEXAS
MOTION TO AMEND
AND CORRECT PETITION
TO THE HONORABLE JUSTICES OF SAID COURT:
Now Comes, Richard Lares, Appellant herein, and files this Motion to
FILED IN
Amend and Correct Petition on Petition for Discretionary RevielOlaH^ (Jb CsT!igp©j\t APPEALS
of will show good cause: CI3 c 0 2~"j
I.
Abel Acosta, Clerk
Appellant submitted a Notice to the Fourth Court of Appeals on 12-04-
2015 that the appellant Received a Partial Incomplete Amended Direct Appeal.Pro
Se Copy of the Brief and requested the rest of it.
II.
Appellant then filed Motion for Extention of Time to File his Petition for
Discretionary Review of which the Honorable Criminal Court of Appeals GRANTED
on 12/11/2015 and Appellant Received on 12/18/2015. The Appeals' Court Extended
the Time to File to February 26,2016.
III.
Appellant, with Respect for the Authority of the Honorable Justices of the
Criminal Court of Appeals, did not want to assume that his Motion for Extention
of Time to File his Petition would be granted and still filed his incomplete
Petition. Now, Appellant Received the portions of his incomplete pro se brief
today, 12-21-2015. For these reasons appellant wishes to File an Amended Pro
Se Petition and for good cause in the interest of justice; with the SAME due
Date of February 26,2016 in place.
IV.
Appellant makes a further Request for Documents that have not been made
part of the Clerk's Record for whatsoever reasons, the Pre-Sentence Report^BSl)
which appellant Requires to Resolve his Claim of Actual/Factual Innocence. The
Honorable 399th Judicial District Court Presiding Judge Juanita Vasquez-Garner
had ORDERED the PSI to be done June 10,2009 after the Plea Hearing, thus the
PSI should be available to appellant.
PRAYER AND CONCLUSION
WHEREFOR PREMISES CONSIDERED, Appellant prays that he be granted his Motion
to Amend and Correct Petition with good cause and further prays that he be pro
vided with a copy of the Pre-Sentence Report(PSl) since case law provides that
it could be used to Resolve Matterial Questions of Guilt or Innocence.
Sincerely,
(UJX-
Richard Lares, Pro Se
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the forgoing was sent to the
Honorable Clerk of the Court of Criminal Appeals, P.O.Box 12308 Capitol Station
Austin, Texas 78711 on 12-21-2015 and appellant further requests that a copy
be sent to the Bexar County District Attorney, Paul Elizondo Tower, 101 W.Nueva
St. 7th Floor, San Antonio, Texas 78205; because appellant is indegent and is
unable to provide a copy.
Respectfully Submitted,
lboCs£^-^1 0C-s^~
Richard Lares, Pro Se
TDCJ-ID #1592255
2400 Wallace Pack Rd.
Navasota, Texas 77868