Garrison, Curtis Allen ( 2015 )

PD-0994-15 PDR. NO. COURT OF CR!»!AUPPE^ IN THE TEXAS COURT OP CRIMINAL APPEALS AUG 18 2015 CITY OF AUSTIN; TRAVIS COUNTY ».; ^siuu?sia, uilsJiT THIRTEENTH COURT OP APPEAtS CITY OP CORPUS CHRISTI, NUECES COUNTY MO. 13-14-00372-CR RED 163RD JUDICIAL DISTRICT COURT COURT OF CRIMINAL APPEALS CITY OP VIDOR, ORANGE COUNTY AUG 18 2G15 TRIAL COURT NO. B-130-137-R Abel Acosta, Clerk CURTIS ALLEN GARRISON, APPELLANT PRO SB* STATE OP TEXAS, APPELLEE. APPELLANT'S PRO SE MOTION FOR EXTENSION OP TIME TO PILE PDR T.R.APP. P. RULE 10.5(b)fI) 02015) TO:THE HONORABLE JUSTICES OP THE COURT OP CRIMINAL APPEALS: INTO COURT COMES, Curtis Alien Garrison, Appellant pro se, hereinafter "Appellant," and pursuant to the applicable rules governing petitions to the Court, requesting that the Court exercises its discrettonay authority to consider the opinions of the; Court of Appeals# and request that the Court, grants him an extension of time, to research the applicable law, and perfect his petition for discretionary review for submission to the Court's clerk, for filing. In support of his request to the;;; Court, Appellant would respectfully show the Court, the following belowt I. Appellant was convicted in the 163rd Judicial District Court, for capital ; murder, and sentenced to an automatic LIPE term of imprisonment, from Orange County, Texas. Appeal was taken to the Thirteenth Court of Appeals, and the Court, denied the appeal July 16, 2015. Under the rules. Appellant's first deadline expires August 16, 2015. Appellant 'has not* requested any extensions prior to this request to the Court. III. JUSTIFICATION POR EXTENSION Appellant's request is based on the following facts: (I) Appellant has no previous litigation experience, or legal back ground and training, and has no procedural experience advancing his arguments, and claims applicable to petitions requesting that the Court, reviews the opinions of a lower Court of Appeals; (2) Appellant is confined, and assigned to a maximum security prison facility, where movement is very limited, and access, to the legal research tools in the prison's law library, is restricted and on the verge of being inadequate* (3) Appellant's access to Inmate litigants who provide inmate to inmate legal assistance to prisoners, is also restricted and limited under the new supervisors, {4) Appellant has no control, over the decisions made by security supervisors to suspend activities, and programs for the general population including direct access to the prison's law library, and the limited ^research material provided in it, {5) Appellant has been unable to obtain the funding to retain a skilled, and GARRISON MPBTt PAGE 2 trained professional lltgator, or attorney; (6) Appellant cannot compel prison officials, to allow him greater access to the legal materials, or the research tools within the law library; and (7) Appellant is emotionally, and mentally impaired after being subjected to the ordeal of a capital murder prosecution, resulting from the shooting deaths of two individuals he knew. APPELLANT'S GOOD PAITH DECLARATION Appellant is requesting that the Court, grants him a ninty (90) day extension," to prepare and perfect his petition to the Clerk for filing. Appellant makes this request for an extension in good faith, and for no other reason, and not for the purpose of delaying the execution of the sentence imposed. Appellant is required to exercise due diligence, throughout the appellate process, and this request to the Court, is intended to discharge Appellant's duty to the courts, to exercise due diligence. SUMMARY AND PRAYER WHEREFORE, PREMISES CONSIDERED, Appellant has shown the Court* an extension of time is justified, and that his first request for an extension should be granted la all things. Appellant respectfully prays, that the Court* will give him ninty days to prepare, and submit his pro se petition for discretionary review from August 16, ,2015. Date? August 2015 ^ Respectfully submitted, Curtis Alien Garrison #1926723, Robertson Unit 12071 P.M. 3522 Abilene, Texas 79601-8799 GARRISON MPET: PAGE 3 CERTIFICATE OF SERVICE 1/ Curtis Allen Garrison, do hereby certify that a true and correct coPy, of the foregoing Motion For Extension Of Time To File PDR, has been served on the State, by U.S. Mail, first class postage prepaid in advance, addressed to the below, on this |/my day of August, 2015: Mr. John D. Kimbrough Criminal District Attorney Orange County District Attorney's Office 801 Division Orange, Texas 77630 Curtis Allen garrison GARRISON MEET: PAGE 4