Case Information
*1
PD-0911-15
CASE NO. 02-14-00411-CR TRIAL NO. CR-12645
RECEIVED IN COURT OF CRIMINAL APPEALS JUL 222015 Abel Acosta, Clerk
IN THE TEXAS COURT OF CRIMINAL APPEALS AUSTIN, TEXAS
FILED IN
COURT OF CRIMINAL APPEALS MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW
JUL 222015 Abel Acosta, Clerk
MORRIS LANDON JOHNSON II. (PETITIONER) V.
THE STATE OF TEXAS (APPELLEE)
MORRIS LANDON JOHNSON II. TDCJ # 1877943
*2 CASE NO. 02-14-00411-CR TRIAL NO. CR-12645
MORRIS LANDON JOHNSON
V.
THE STATE OF TEXAS
| | IN THE TEXAS COURT | | :--: | :--: | | | OF | | | | | | CRIMINAL APPEALS |
MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE JUDGES OF SAID COURT:
NOW COMES MORRIS LANDON JOHNSON II., 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 PROCEEDURE, AND FOR GOOD CAUSE SHOWS THE FOLLOWING: 1.) THIS CASE WAS ON APPEAL IN COURT OF APPEALS FOR THE SECOND DISTRICT OF TEXAS 2.) THE JUDGEMENT WAS MADE ON JUNE 18TH, 2015. 3.) THE CASE WAS STYLED MORRIS LANDON JOHNSON II. V. THE STATE OF TEXAS. CASE NO. 02-14-00411-CR. 4.) NO MOTION FOR REHEARING OR EN BANC CONSIDERATION WAS FILED IN THIS CASE. 5.) PETITIONER REQUEST THE COURT TO GRANT SIXTY (60) DAYS - TIME EXTENSION.
*3 6.) PETITIONER HAS LIMITED ACCESS TO COURTS (LAW LIBRARY TIME) DUE TO OVER CROWDED FACILITY, ON-OFF ROLLING SECURITY LOCKDOWNS. 7.) 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. 8.) THIS CASE WAS ORIGINALLY A SECOND DEGREE FELONY ENHANCED TO 5 TO 99 YEARS - WHERE PETITIONER SUFFERED A PUNISHMENT SENTENCE OF 40 YEARS CONFINEMENT. 9.) PETITIONER IS CURRENTLY INCARCERATED. 10.) PETITIONER, TO DATE, IS DILIGENTLY EXAMINING THE APPELLANT BRIEF AND ALL LOWER COURT PROCEEDINGS AND REQUIRES ADDITION--AL TIME TO SUFFICIENTLY ANALIZE MATERIAL CONTAINED THEREIN--IN ORDER TO EFFECTIVELY PREPARE A MEANINGFUL PETITION IN THIS CASE. 11.) PETITIONERS DISCRETIONARY REVIEW IS PRESENTLY DUE ON JULY 18, 2015. 12.) PETITIONER RESPECTFULLY REQUEST AN EXTENSION OF TIME OF SIXTY (60) DAYS FROM THE PRESENT DUE DATE OF JULY 18, 2015.
WHEREFORE PREMISES CONSIDERED, PETITIONER PRAYS THAT THE COURT GRANT THIS MOTION FOR EXTENSION OF TIME TO FILE A PETITION FOR DISCRETIONARY REVIEW-AND FOR SUCH OTHER-FURTHER RELIEF AS THE COURT DEEM APPROPIATE.
*4 RESPECTFULLY SUBMITTED: MORRIS LANDON JOHNSON II.
TDCJ NO. 1877943 2661 FM 2054 TENNESSEE COLONY, TX.
*5
CERTIFICATE OF SERVICE
I, MORRIS LANDON JOHNSON II., TDCJ #1877943, PRESENTLY CONFINED IN THE TX. DEPT. OF CRIM.-J.-CID @ THE H.H. COFFIELD UNIT IN ANDERSON COUNTY DECLARE UNDER THE PENALTY OF PERJURY AND HEREBY CERTIFY THAT ONE (1) ORIGINAL OF THE ENCLOSED INSTRUMENT (MOTION FOR EXTENSION OF TIME) WAS PLACED IN THE PRISON UNIT MAILING SYSTEM ON JULY 17, 2015 TO FORWARD VIA USPS, FIRST CLASS POSTAGE TO: 1.) 'ABEL ACOSTA' (CLERK) TEXAS COURT OF APPEALS P.O. BOX 12308 (CAPITOL STATION)
AUSTIN, TEXAS 78711 - 2308 EXECUTED ON THIS 17TH DAY OF JULY, 2015.
MORRIS LANDON JOHNSON II. TDCJ NO.#1877943
2661 FM 2054 TENNESSEE COLONY, TEXAS 75884 - 5000