Longoria, Daniel Frank Jr. ( 2015 )

PD-0768-15 PDR NO. DANIEL FRANK LONGORIA JR. Appellant, IN THE COURT OF CRIMINAL v. APPEALS AT AUSTIN,. H5QC£L.W1W1^ ,,_ COURT OF CRfiWTNAL APPEALS THE STATE OF TEXAS Appellee. JUW 2 6 2015 MOTION FOR AN EXTENTION OF TIME TO FILE A Abel ACGSta Clerk PETITION FOR DISCRETIONARY REVIEW GOMES NOW, Daniel Frank Longoria Jr., Appellant in the above styled and numbered cause, and files his motion for an extention of time^pursuant to rule 68.2(c) of the Texas Rules of Appfen/ia^e COURT OF CRIMINAL APPEALS Procedure, and shows this Honorable Court GOOD CAUSE to GRANT JUN 26 2015 this motion as follows: 1- The Appellant was affirmed on June 25, 2014, Afe^el $S@SMiCUfork District Court of Appeals at Beaumont. See Longoria v. State, No. 09-13-00169-GR (Tex.App. —Beaumont June 25, 2014)(not design ated for publication). The Appelant filed a Habeas proceeding seeking for an out-of-time Petition, and this Honorable Court Gra nted relief on June 3, 2015. See Ex Parte Daniel F. Longoria, Jr. No. WR-83,036-01 (Tex.Crim.App. June 03, 2015)(Not designated for publication). 2* There has been ho motion for rehearing filed or en banc reconsideration filed, that the Appellant knows of. Additional ly, there has been- no other extention of time filed within this Honorable Court. 3* The Appellant is seeking for a 60 day extention in order for the Appellant to properly file his Petition in a proper man ner. The due date is currently July 3, 2015. The 60 day exten- page 1 tion will set the proposed date to September 1, 2015. 4* The Appellant is currently without counsel for his help, and is proceeding in the pro se status. 5- Being a layman in the law, the Coffield Unit's law library only allows for offenders to have 10-15 hours per.week to conduct their research, properly prepare for filing, and reply to any Court documents required. 6* The Appellant believes that he can meet the deadline on September 1, 2015, in order-for. this Honorable Court to review in a timely manner. PRAYER The Appellant prays that this Honorable Court will GRANT this motion and reset the due date to September 1, 2015, or in the air ternative, reset the current due date to a reasonable time frame in order for the Appellant to properly file his petition on his own behalf./ INMATE DECLARATION I, Daniel F. Longoria Jr .,. #01851803 , being currently incar cerated in the TDCJ-CID Coffield unit in. Anderson County, Texas, declares that the foregoing is true and correct under the penalty of perjury. EXECUTED THIS DAY OF JUNE 15, 2015. Daniel Frank 'tongoria Jr. Coffield unit -- #01851803 2661 FM 2054 Tenn.Colony, Tx. 75884 Pro se. PROOF OF MAILING I, Daniel F. Longoria Jr., #01851803, declares under the pen- page 2 alty of perjury that I have placed this motion in the internal mail box of the Coffield unit in Anderson County, Texas on June 15, 2015. Daniel FrankT^ongoria Jr. Coffield unit -- #01851803 2661 FM 2054 Tenn.Colony, Tx. 75884 Pro se. page 3 of 3