PD-0238-15 RECEIVED IN COURT OF CRMNAL APPFALS IN THE COURT OF CRIMINAL APPEALS 03 2015
WILLIAM HERNANDEZ APPELLANT ifk
APPELLANT COURT NO. 01-13-00825-CB VS. TRIAL COURT NQ,vJ.22516F''-ED IN •MS TOF CRIMINAL APPEAL! THE STATE OF TEXAS APPELLEE § MAR 03 2:;5 MOTION FOR EXTENTION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW Abel Acosta, Clerk TO THE HONORABLE COURTt
COMES NOW, HILLIAN HERNANDEZ, PRO SE MOVANT AND SUBMITS THIS MOTION TO EXTEND TIME FOR FILING A PROPER AND EFFECTIVE PETITION FOR DISCRETIONARY REVIEW AND FOR GOOD CAUSE RESPECTFULLY SHOWS THE FOLLOWING:
APPELLANT'S PETITION FOR DISCRETIONARY REVIEW IS DUE THE 13TH, DAY OF MARCH 2015.
II
WILLIAM HERNANDEZ, IS A PRO PETITIONER AND MOVES THIS COURT TO GRANT AN EXTENSION OF TIME TO FILE A TIMELY AND PROPER PETITION FOR DISCRETIONARY REVIEW AND RESPECTFULLY STATES*
1) MOVANT HAS EXERCISED DUE DILIGENCE IN AN ATTEMPT TO PRODUCE A TRUE AND CORRECT COPY OFt (A) APPELLANT BRIEF FILED BY KURT B. WBKTZ. PREVIOUS APPELLANT COUNSELi (B) STATES BRIEF AND (C) COPY OF OPINION HANDED DOWN. BY THE FIRST COURT OF APPEALS AT HOUSTON. MOVANT HAS MADE NUMEROUS ATTEMPTS TO OBTAIN SAID DOCUMENTS BUT DO TO THE INTENTIONAL NEGLECT OF PREVIOUS APPELLANT COUNSEL. HE HAS YET TO RECEIVE ANY DOCUMENTS, LET ALONE A RESPONSE TO MOVANT'S TIMELY REQUESTS
2) MOVANT SEEKS A (90) DAY EXTENSION OF TIME TO FILE HIS P.D.R, WHICH WOULD MAKE MOVANT'S HESPONSE DUE THE 15 DAY OF JUNE, 2015.
3) THE EXTENSION OF TIME IS NECESSARY BECAUSE MOVANT IS PRO SE AND REQUESTS THIS HONORABLE COURT TO, REQUIRE THE FIRST COURT OF APPEALS AND/OR PREVIOUS APPELLANT COUNSEL TO TURN OVER THE ABOVE NAMED DOCUMENT INSOFAR THAT MOVANT'S DUE PROCESS
GUARANTEE TO AN EFFECTIVE APPEAL CAN BE OUELY EXE&CISED BY MOVANT IN THAT HE IS ABLE TO EFFECTIVELY FILE HIS P.D.R. 4) MOVANT RECEIVED A 'WHITE CARD' FROM THE FIRST COURT OF APPEALS ON THE J9TH DAY OF FEBRUARY , 2015, WITHOUT AN OPINION. DUE TO THE NEGLECT OF APPELLANT COUNSEL, MOVANT HAS NO KNOWLEDGE AS TO THE BASIS OF HIS APPEAL, NOR THE REASON IN
WHICH IT WAS DENIED.
5) AS OF FEBRUARY 19TH • 2015, AS BEING THE DATE OF NOTIFICATION BY THE FIRST COURT OF APPEALS TO MOVANT. SAID NOTIFICATION STATED THAT A DECISION WAS REACHED
ON THE 2ND DAY OF DECEMBER 2014, CLEARLY ESTABLISHING HNCONSTITIJTIONAL TIME
RESTRAINTS TO MOVANT.
FOR THESE REASONS, MOVANT REQUESTS THIS HONORABLE COURT TO RENDER AN ORDER EXTENDING THE TIME FOR FILING MOVANT'S PETITION FOR DISCRETIONARY REVIEW
AND TO INCLUDE A FULL (90) DAYS SO MOVANT CAN PERFECT HIS PETITION.
RESPECTFULL SUBMITTED
WILLIAM HERNANDEZ PRO SE LITIGANT TDC... 1889157 3.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT THIS DOCUMENT WAS PLACED IN THE
H.S P.O. MAIL BOX AT THE W.P. CLEMENTS UNIT IN POTTER
COUNTY TEXAS, AND MAILED TOs TEXAS COURT OF CRIMINAL
APPEALS, AUSTIN. ON THE 2AND, DAY OF FEBRUARY. 2015
RESPECTFULLY SUBMITTED y
WILLIAM HERNANDEZ PRO SE LITIGANT
DECLARATION
I WILLIAM HERNANDEZ, HEREBY DECLARE UNDER THE PENALTY
OF PERJURY, AND THE