Case Information

*1 , FILED IN PD-0330-15 COURT OF CRIMINAL APPEALS COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 7/8/2015 11:08:03 PM

July 9, 2015 Accepted 7/9/2015 5:01:42 PM ABEL ACOSTA CLERK ABELACOSTA. CLERK PD-0330-15

COURT OF CRIMINAL APPEALS OF TEXAS r ^ JAY SANDON COOPER v. A- STATE OF TEXAS

MOTION TO EXTEND TIME TO FILE MOTION FOR REHEARING

NOW COMES JAY SANDON COOPER, and makes this first motion to extend the time to file a motion for rehearing. In support thereof, Mr. Cooper shows: This Court refused Defendant's Petition for Discretionary Review on June

24, 2015. Fifteen days thereafter would be July 9, 2015, on which date Defendant expects that his Motion for Rehearing or this Motion to Extend Time should be due. Defendant seeks an extension of thirty (30) days, to August 8, 2015. Defendant was released from the Collin County Jail on June 30, 2015, and

did not learn of this Court's refusal of his PDR until a date thereafter. During his incarceration of 14 days, Defendant was unable to stay abreast of recent court rulings that might impact this case. As well, because of his confinement, Defendant was unable to stay current on this and other cases, and needs some additional time to do justice with this and other pending cases. *2 Because Defendant was arrested not for DWI, but for refusing to participate

in roadside field sobriety tests that are not required by law, Defendant anticipates briefing this Court on an extension of the landmark case: Miranda v. Arizona. 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 ... (1966). There have been no previous extensions sought or granted to file

Defendant's Motion for Rehearing in this case.

PRAYER Defendant requests that this Court grant an extension of thirty (30) days to

August 8, 2015, for Defendant to file his Motion for Rehearing.

July 8, 2015.

Respectfully submitted,

1520 JanwoodDr.

Piano, Texas 75075

(972)358-8999

NO FAX

JaySandonCooper@gmail.com

DEFENDANT

CERTIFICATE OF CONFERENCE Defendant spoke with Assistant District Attorney Karla Hackett on July 8, 2015, and the State expressed no position with regard to the relief requested in the foregoing motion.

CERTIFICATE OF SERVICE A true and correct copy of the foregoing and attached documents were electronically served to the following recipients, if that option was available through the electronic filing manager, and if not, it was mailed on July 8, 2015: Karla R. Hackett

Assistant District Attorney

Grayson County, Texas

200 S. Crockett, Suite 116A

Sherman, Texas 75090

and

Lisa C. McMinn

State Prosecuting Attorney

P.O. Box 13046

Austin, Texas 78711-3046