Pierce, Joseph Michael

Opinion

* Gr^ pn-Odsi'15

PIERCE , JOSEPH MICHAEL, § IN THE TEXAS COURT

(Appellant) § OF CRIMINAL APPEALS,

VS, ^ECBVF™ «r § AUSTIN, TEXAS COUmxi?CRK;ii;Al"APF"ALS

STATE, OF TEXAS, OCT 29 2015 § (Appellee) -)"¥

APPELLANT'S MOTION FOR EXTENSION OF TIME

TO FILE MOTION FOR REHEARING PURSUANT TO T.R.A.P. RULE 79

Appellant, JOSEPH MICHAEL PIERCE, proceeding pro se in the

above styled and numbered cause, respectfully moves this court

for an extension of time to file his Motion For Rehearicrai pursuant

to T.R.A.P. Rule 79. In support thereof, Appellant Wu9§Cln^)^ALAPPEALS the following: U*J &J L>3

1. On IQ" J*/-36J5 "the Texas Court of Criminal Appeals' r9f^!§eG,erk Appellant's Petition For Discretionary Review, in Cause No'.

ft)-0651-If) •

2. Pursuant to T.R.A.P. Rule 79, Appellant is entitled to pursue

a Motion For Rehearing of the Court's refusal of his Petition

For Discretionary Review.

3. Appellant certifys that, his Motion For Rehearing is based

on substantial intervening circumstances or other significant

circumstances which are specified in the motion, and is made

in good faith, and not for delay purposes.

1. 4. Appellant is proceeding pro se and indigent and has very

limited litigation skills required for preparing and filing

a meaningful Motion For Rehearing.

5. Appellant believes in good faith that his Motion For Rehearing

has substantial merit, thus, requiring to be reviewed in the

interest of justice.

6. Appellant, is not pursuing a Motion For Rehearing to delay

these appellate proceedings, nor to harrass Appellee(s) in any

manner.

WHEREFORE, PREMISES CONSIDERED, Appellant, prays this Court

grant this motion, extending the deadline date for filing

Appellant's Motion For Rehearing to IJ" l3~ pjOlS -providing an additional (15) days from the original deadline date of

/Q^cx 7 c/U/O , to file his Motion For Rehearing. Executed on this c* / " day of QCtOq€C , 2015, ,

oseph Michael Pierce

OATH

I, JOSEPH MICHAEL PIERCE, do declare under the penalty of

perjury pursuant to Tex.Civ.Prac.Rem. Code, §132.001 - §132.003,

that the facts stated herein my Motion For Extension of Time

to file a Motion For Rehearing pursuant to T.R.A.P. Rule 79,

is true and correct.

Executed on this C? \ day of (jCj-Qo&P , 2015

^

I, JOSEPH MICHAEL PIERCE, do certify that,a true and correct

copy of Appellant's Motion For Extension of Time to File a Motion

For Rehearing Pursuant to T.R.A.P. RULE 79, was served on Appellee

by U.S. Mail, postage prepaid, addressed to the following addresses

Mr. Michael West (Asst.Dist.Attny.)

100 North Broadway, 4th Fl.

Tyler, Texas, 75702

AND

State Prosecuting Attorney

P.O. Box 12405

Austin, Texas, 78711

Executed on this 3\ day of O&oher 2015

' \faj>fh

3060 FM 3514 #1919200 (Stiles Unit)

BEAUMONT, TEXAS, 77705