Case Information
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twel'fth court of appeal's Oelanda Letrepg Player MO. 12-1F-00259- CI/ l/s Trial Cour': -14
12ttiCcx*t o' Appeals ;<srict The State of Texas MOTION FDR EXTENSION OF TIME
Plaintiff has brought before this Court a suit Tor his release from pursuant to 11.07 hbabeas corpus and a Oarnishment suit for Plaintiff's Plaintiff will need to seek a extension of time in order to Amend his suit and file a 11.07 habeas corpus application. Plaintiff -Applicant needs to obtain forms and to have access to the Court's by means of being afforded time to go to the law library in order to review the law necessary to file the Amendments and suit's filed already with the Court.
Plaintiff-Applicant has deadlines for filing these items set as November 30, 2015, the information needed to amend to show jurisdiction of this court, and needs law library time to complete these tasks and seeks an extension of time of 60 days.
Plaintiff has not had time since the month of October order of this Court as the Plaintiff will show this Court the whole month of October he was on "L'ock-down" confined to his cell due to "security measures of the wynne Unit's (6) Month annual cell searches and shack-down of all inmate-offenders on the Unit, which denied Plaint iff-App1icant of access to the Court by denying access to the law library and ability of going to commissary to purchase stamps to mail out any legal correspondence to the Court's which also caused Plaintiff of the ability to file any type of correspondence to the Court's.
Plaintiff was also impended by the official's of the Wynne Unit by keeping Plaintiff locked-up, in Plaintiff's cell after it was completed,
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*2 after the searches were completed by again locking Plaintiff down du to the "Electricity" going out for another two weeks denying Plaintiff of lights to be able to see anything or being able to see good enough write any Iwgal matters because Plaintiff didn't have lights to see good enough to do any legal research in these matters. Plaintiff was placed under these conditions for a total of four weeks without even being able to send out mail to anyone because the mailroom officer's were not picking mail out going up from the cells where Plaintiff was confined. Therefore Plaintiff seek (60) days extension. To comply with the Court orders.
Plaintiff will suffer a manifest injustice, for a extension of time if not granted one. See Holland vs. Florida, 560 U.S. 631, 645 (2010).
Plaintiff contends he is entitlted to relief in these matters.
Respectfully Submitted &&
AaA -
irjPj>/jLlhoJ Delanda Letregg Pluayer (—^ TDC3-ID#1955184 Wynne Unit
810 F.M. 2821
Huntsville, Texas 77349
Plaintiff Delanda Letregg Player TDC3-ID* 1955184, being presently
incarcerated at the Wynne Unit of the Texas Department of Criminal justice-
Institutional Division, in Walker County, Texas, declare under penalty of perjury that the foregoing is true and correct. Executed on this c^J>~Day of /V CQ^)y^yy/\-Py^J) 2015.
Delanda Letregg Player (J ~ I TDCj-ID#1955184 Wynne Unit
810 F.M. 2821
Huntsville, Texas 77349