COMES WON JAMES AFTHUR BRown, PETITOWER IN THE ABOVE - ENTELLED AND NUMBERED CAUSE, AND MOVES THIS COURT TO EXTEND THE TIME TO FILE A (PDR) PETITION FOR DISCRETIONARY REVIEW TO PREVENT THE MISCAFRIAGE OF SUSTICE, AND SHEWS IN SUPPORT OF THIS MOTION!

I. THE ATTORNEY REFRESENTING THE DEFENDANT ON APPEAL DID NOT, WITHIN FIVE DAYS AFTER THE OPIONS HANDED DANN, SEND A COPY OF THE OPION AND SUBGRENTS, ALONG WITH HOTETICATION OF THE DEFENDANTS RIGHT TO FILE A PRO SE PETITION FOR DISCRETIONARY REVIEW UNDER RULE 68. THE THIRD COURT OF APPEALS AFTERMED THE TREAL COURT'S SUBGRENTS OF CONVICTION MAY, 12, 2015. ATTORNEY SENT USA

*2 CERTIFIED MAIL TO THE SMITH WHT MAY 21,2015. THE CERTIFIED MAIL HAS A U.S. POSTAL DATE SUNE 4, 2015. THE PETITONER RECEIVED THE CERTIFIED MAIL ON SUNE 9,2015 WHERE HE SIGNED FOR IT FROM THE PRISON OFFICIAL FOR THE MAIL. FROM MY WIDERSTAND THE DEARLINE IS SUNE 10, 2015, THE DEFENDANT SUST BECOVERED HE HAD AN ATTORNEY ON DIRECT APPEAL SUNE 9, 2015, A DAY BEFORE THE DEROLINE.

II. THE DATE ON WHECH THE CONSTITUTIONAL PIGHT ASSEPTED WAS INITIALLY RECONIZED BY THE PETITONER, ON WHICH THE JUDGMENT BECAME FINAL BY THE CONCLUSION OF THIRD COURT OF APPEALS OR THE EXPERATION OF TIME FOR FILING A FOR CONTESTING APPELLATE COURT'S AFFIRMATION ON TRIAL COURT'S JUDGMENT OF CONVICTION, WHICH ALL ARE EXTERNAL TO HIM.

III. THIS CAUSE FAIRLY APPEARS TO REST PIZMARILY ON FEDERAL LAW OR TO BE INTERWOVEN WITH FEDERAL LAW, WITH QUESTION REGARDING ADESMACY OF STATE RULE ON WHETHER, IT IS FERMLY ESTABLISH AND REGULARLY FOLLOWED, THAT IS, IN FALLURE TO GIVE A PARTY FAIR NOTICE OF ADVERSE ACTION AND PROCEDURE.

IV. EXTRAORDINARY CIRCUMSTANCES ESTABLISHING A MISCARRIAGE OF SUSTICE, AND THE LATE PETITION WHICH IS BASED ON THE CODIFICATION OF THE EQUISTABLE DOCTRINE; WHICH INCLUDE ABSENCE OF AVAILABLE STATE CONPECTIVE PROCESS AND EXISTING CIRCUMSTANCES THAT PENDER SUCH PROCESS INEFFECTIVE TO PROTECT THE PIGHTS OF THE

*3

PETITIONER IF THES MOTION IS NOT GRANTED. V. THE Above cause include a criminal conviction in treal court cause bi-bc-13-300630 that rest on FUNDAMENTAL ERROR AND UNWARVABLE RIGHTS ENTITLED TO DEFEUDANTS

VI. FAELURE TO SET ASIDE THE STATE'S DECISION AND EXTEND THE TIME BY 30 DAYS OR GRANT TOLEING AFTERDING FAIR OPERTWIPY TO PRESENT CLAZMS WILL BE A MSCARRIAGE OF SUSTICE.

WHEREFORE, PETITIONER PRAYS THE COURT EXTEND THE TIME BY 30 - DAYS OR GRANT EQUITABLE TOLEING AND SET ASIDE THE DECISION OF THE COURT BELOW.

SURF 9,2015

ORDER

( ) GRANTED ( ) DENTED