Cooper, Jay Sandon ( 2015 )


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  • ,               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
    JAY SANDON COOPER
    v.
    rA- ^
    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:
    1.      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.
    2.      Defendant seeks an extension of thirty (30) days, to August 8, 2015.
    3.      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.
    Defendant's Motion to Extend Time to File Motion for Rehearing: Page 1
    4.    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).
    5.    There have been no previous extensions sought or granted to file
    Defendant's Motion for Rehearing in this case.
    PRAYER
    6.    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,
    /s/ Jay Sandon Cooper
    Jay Sandon Cooper
    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.
    Defendant's Motion to Extend Time to File Motion for Rehearing: Page 2
    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
    /s/ Jay Sandon Cooper
    Jay Sandon Cooper
    Defendant's Motion to Extend Time to File Motion for Rehearing: Page 3
    

Document Info

Docket Number: PD-0330-15

Filed Date: 7/14/2015

Precedential Status: Precedential

Modified Date: 9/29/2016