IN THE ^^OFmmuFPB^

COURT OF CRIMINAL APPEALS

of texas JUL 3 0 2015

Joseph Michael Pierce,

Appellant/Petitioner;

vs.

The State of Texas,

Appellee/Respondent.

JUL 3 0 2S:3

TO THE HONORABLE COURT OF"CRIMINAL APPEALS OF TEXAS:

COMES NOW, Joseph Michael Pierce, by and through himself, pro se, dkbaihecosta, Clerk

above-numbered cause and respectfully moves::this Honorable Court to grant,

leave to file an original copy only of the Petition for Discretionary Review

and to suspend any other procedural defect :;and:: in support cthereof would show

the Court the following:

1. The style and appeal.. number in the Tyler Court of Appeals is: Joseph

Michael Pierce v. The State of Texas, No. 12-14-00073-CR.

2. The Appellant moves that, pursuant:to Rule 2, Texas Rules of Appellate

Procedure, this Court suspend Rule 9.3(£>•), Texas Rules of Appellant Procedure,

that requires the filing of eleven (11) copies of the Petition for Discretion

ary Review with the Court.

3. The Appellant moves that, pursuant to Rule 2, Texas Rules of Appellate

Procedure, this Court suspend any defect:'found inutheipldadingsr.or filings.lof

the Petition for Discretionary Review that would violate any rule of the Texas

Rules of Appellate Procedure;

4. The facts relief upon to show good cause for this request are, as

follows: Appellant is indigent and incarcerated and does not have access

to a photo copier. Appellant is presently not represented by counsel and is

filing a Petition for Discretionary Review pro se.

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests that this

Honorable Court GRANT leave to file an original copy only of the Petition for

No.

Appellant's Motion Requesting

Leave to File an Original Copy

Only of the Petition for

Discretionary Review and to FILED IN

Suspend Other ProcedurattCMEegfsCRIMINAL APPEALS

Appellant's Rule 2 Motion for Copies and Procedural Defects-.- Page 1
Discretionary Review with the Court and to suspend any procedural defect that

may be found in the pleadings or filings. In the alternative, Appellant asks

the Court that the petition or any other filing be returned to Appellant so

that he may,be able to correct the error for the Court.

Respectfully submitted,

Q (\uLoJl

Joseph mchael Pierce

#01919200

Stiles Unit

3060 FM 3514

Beaumont, Texas 77705

CERTIFICATE OF SERVICE

I, Joseph Michael Pierce, certify that a true and correct copy of the

foregoing motion has been mailed, U.S. Mail, postage prepaid, to the Smith

County Criminal District Attorney's Office, 100 North Broadway, 4th Floor,

Tyler,:• Texas 75702, and to the State Prosecuting Attorney; P.O. Box 12405,

Austin, Texas 78711, on this the ()}\ aay of July, 2015.

lAjckcJ IflU^L

eph Michael Pierce

VERIFICATION OR INMATE DECLARATION

I, Joseph Michael Pierce, TDCJ-CID #01919200, DOB 08-09-1978, being pres

ently incarcerated in the Stiles Unit of the Texas Department of Criminal

Justice, Institutional Division, Beaumont, Jefferson Countyy Texas, declare

(certify, verify, or state) under penalty of perjury that I have read the

above and foregoing motion, that the facts contained herein are true and cor

rect, and that this motion is made in good faith.

EXECUTED, this the nH day of July, 2015

Joseph Michael Pierce

Appellant's Rule 2 Motion for Copies and Procedural Defects - Page 2