Thomas, Joshua Jerrod ( 2015 )

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
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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
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