Jones, Lonnie James Jr.

• Court: Court of Appeals of Texas
• Decided: July 27, 2015
• Docket: PD-0953-15
• Status: Published

Opinion

PD-0953-15

CASE No. 09-13-00459-CR

TRIAL No. 13-03-03256-CR

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COURT OF CR»!ALAPPFALS IN THE TEXAS COURT JUL 27 2015 OF

CRIMINAL APPEALS im?H

AUSTIN, TEXAS

MOTION FOR EXTENSION OF TIME TO FILE

PETITION FOR DISCRETIONARY REVIEW

LONNIE J. JONES Jr. FILED IN COURT OF CRIMINAL APPEALS (PETITIONER)

vs . JUL 27 2015

THE STATE OF TEXAS Abel Acosta, Cierk (APPELLEE)

LCNNIE J. JONES Jr. TDCJ # 1889803 (PRO SE) CASE No. 09-13-00459-CR

LONNIE JAMES LONES Jr § IN THE TEXAS COURT § § OF vs. § § CRIMINAL APPEALS § THE STATE OF TEXAS § AUSTIN, TEXAS

TO THE HONORABLE JUDGE OF SAID COURT:

NOW COMES, LONNIE JAMES JONES J r . , APPELLANT-PETITIONER IN THE ABOVE

STYLED AND NUMBERED CAUSE, MOVES THIS COURT TO GRANT AN EXTENSION OF TIME

TO FILE A PETITION FOR DISCRETIONARY REVIEW, PURSUANT TO RULE 68.2(c) OF THE' TEXAS RULES OF APPELLATE PROCEDURE, AND FOR GOOD CAUSE SHOWS THE FOLLOW

ING:

1.) THIS CASE WAS ON APPEAL IN THE COURT OF APPEALS FOR THE NINTH (9th) DISTRICT.

2.) THE JUDGEMENT WAS MADE ON JUNE 24, 2015.

3.) THE CASE WAS STYLED LONNIE JAMES JONES Jr. vs. THE STATE OF TEXAS,

CASE No. 09-13-00459-CR.

4.) NO MOTION FOR REHEARING -or- EN BANC CONSIDERATION WAS FILED IN THIS

CASE.

5.) PETITIONER REQUEST THE COURT TO GRANT A SIXTY (60) DAY TIME EXTENSION.

6.) PETITIONER HAS LIMITED ACCESS TO COURTS, (LAW LIBRARY TIME), DUE TO OVER CROWDED FACILITY, ON-OFF ROLLING SECURITY LOCKDOWNS.

7.) PETITIONER IS A PRO SE LITIGANT WITH LIMITED LAW SKILLS, HAVING TO

RELY ON DIALATORY - ELECTRONIC ACCESS TO UPDATE CASE LAW - MATERIALS

NEEDED AND SHOULD NOT BE HELD TO THE STRINGENT STANDARDS OF A LICENSED

ATTORNEY.

- 1 - 8.) THIS CASE WAS ORIGINALLY A THIRD (3rd) DEGREE FELONY ENHANCED TO FIRST (1st) DEGREE, (5 - 99), PUNISHMENT - WHERE PETITIONER SUFFERED FORTY (40) YEAR T.D.C J.-C.I .D. CONFINEMENT.

9.) PETITIONER IS CURRENTLY INCARCERATED.

10.) PETITIONER, TO DATE, IS DILIGENTLY EXAMINING THE APPELLANT BRIEF AND ALL LOWER COURT PROCEEDINGS AND REQUIRES ADDITIONAL TIME TO SUFF

ICIENTLY ANALYZE MATERIAL CONTAINED THEREIN IN ORDER TO EFFECTIVELY

PREPARE A MEANINGFUL PETITION IN THIS CASE.

11.) PETITIONER HAS A DOCUMENTED HISTORY OF MENTAL HEALTH ILLNESS AND TO DATE SUFFERS FROM SUCH - ESSENTIALLY REQUIRES EXTRA TIME TO PERFECT

A PETITION FOR DISCRETIONARY REVIEW.

12.) PETITIONER'S DISCRETIONARY REVIEW IS PRESENTLY DUE ON JULY 24, 2015.

13.) PETITIONER RESPECTFULLY REQUEST AN EXTENSION OF TIME TO FILE HIS PETITION FOR DISCRETIONARY REVIEW OF SIXTY (60) DAYS FROM THE PRESENT DUE DATE OF JULY 24, 2015.

WHEREFORE PREMISES CONSIDERED, PETITIONER PRAYS THAT THE COURT GRANTS

THIS MOTION FOR EXTENSION OF TIME TO FILE A PETITION FOR DISCRETIONARY REVIEW,

AND FOR SUCH OTHER -and/or- FURTHER RELIEF/'AS THE COURT DEEM APPROPRIATE.

RESPECTFULLY SUBMITTED,

LONNIE JAMESJONES Jr. TDCJ # 1889803 H.H. COFFIELD UNIT 2661 FM 2054 TENNESSEE COLONY, TEXAS 75884-5000

- 2 - CERTIFICATE OF SERVICE

I, LONNIE JAMES JONES Jr., TDCJ # 1889803, PRESENTLY

CONFINED IN THE TEXAS DEPARTMENT OF CRIMINAL JUSTICE - C.I.D.

AT THE H.H. COFFIELD UNIT IN ANDERSON COUNTY, DECLARE UNDER

THE PENALTY OF PERJURY AND CERTIFY THAT A TRUE AND CORRECT COPY

(TOTALING 3 pages) OF THE ENCLOSED INSTRUMENT, MOTION FOR EXTEN SION OF TIME, WAS PLACED IN THE PRISON LEGAL MAILING SYSTEM

ON JULY 23, 2015, TO FORWARD via U.S.P.S. FIRST CLASS POSTAGE

TO: TEXAS COURT OF CRIMINAL APPEALS, ATTN: "ABEL ACOSTA" (CLERK), P.O. BOX 12308, CAPITOL STATION, AUSTIN, TEXAS 78711-2308.

LONNIE JAWK JONES Jr. TDCJ # 1889803 H.H. COFFIELD UNIT 2661 FM 2054 ''' TENNESSEE COLONY, TEXAS 75884-5000

UNSWORN DECLARATION

I, LONNIE JAMES JONES Jr., AM THE PETITIONER AND BEING

PRESENTLY INCARCERATED IN THE TEXAS DEPARTMENT OF CRIMINAL JUST

ICE - C.I.D., DECLARE UNDER PENALTY OF PERJURY THAT, ACCORDING

TO MY BELIEF, THE FACTS STATED IN THE ABOVE AND FOREGOING ARE

TRUE AND CORRECT.

SIGNED ON JULY 23, 2015. , , __ .

LONNIE JAMES JONES Jr. TDCJ # 1889803 (PRO SE)