CASE No. 09-13-00459-CR

TRIAL No. 13-03-03256-CR

IN THE TEXAS COURT

OF

CRIMINAL APPEALS

AUSTIN, TEXAS

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COURT OF CR»!ALAPPFALS

JUL 27 2015

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MOTION FOR EXTENSION OF TIME TO FILE

PETITION FOR DISCRETIONARY REVIEW

LONNIE J. JONES Jr.

(PETITIONER)

vs .

THE STATE OF TEXAS

(APPELLEE)

FILED IN

COURT OF CRIMINALAPPEALS

JUL 27 2015

Abel Acosta, Cierk

LCNNIE J. JONES Jr.

TDCJ # 1889803

(PRO SE)
CASE No. 09-13-00459-CR

TRIAL No. 13-03-03256-CR

LONNIE JAMES LONES Jr § IN THE TEXAS COURT

§

§ OF

§

§ CRIMINAL APPEALS

§

§ AUSTIN, TEXAS

vs.

THE STATE OF TEXAS

MOTION FOR EXTENSION OF TIME TO FILE

PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE JUDGE OF SAID COURT:

NOW COMES, LONNIE JAMES JONES Jr., 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.)

2.)

3.)

4.)

5.)

6.)

7.)

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

DISTRICT.

THE JUDGEMENT WAS MADE ON JUNE 24, 2015.

THE CASE WAS STYLED LONNIE JAMES JONES Jr.

CASE No. 09-13-00459-CR.

vs. THE STATE OF TEXAS,

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

CASE.

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

PETITIONER HAS LIMITED ACCESS TO COURTS, (LAW LIBRARY TIME), DUE

TO OVER CROWDED FACILITY, ON-OFF ROLLING SECURITY LOCKDOWNS.

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.CJ.-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,

- 2 -

LONNIE JAMESJONES Jr.

TDCJ # 1889803

H.H. COFFIELD UNIT

2661 FM 2054

TENNESSEE COLONY, TEXAS

75884-5000
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)