Keels, James Kenneth Jr. ( 2015 )

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