Ebong, Iniubong ( 2015 )

PD-0566-15
IN THE
COURT OF CRIMINAL APPEALS RECEIVED IN
AT AUSTIN, TEXAS CCUR1 QF CRIMINAL APPEALS
MAY 12 2Q15
No. 14-14-00070-cr Abel Acosta, Clerk
Iniubong Ebong, Appellant-Petitioner, Pro se
FILED IN
v- COURT OF CRIMINAL APPEALS
STATE OF TEXAS, Appellee MAY 1^ 2015
Abel ArnstR Clerk
OnAppeal from the 351st Judicial District Court
of Harris County, Texas, Cause Number: 134974
Appellant Ebong's First Motion for Extension of Time to File Petition for
Discretionary Review with Brief in Support
COMES NOW, Iniubong Ebong, TDCJ-CID#01908828, Appellant-Petitioner, pro
se, in the above-styled and numbered appeal and files this, his First Motion for Extension
of Time to File His Petition for Discretionary Review with Brief in Support and in support
thereof, would respectfully show the Court as follows:
I.
Procedural History
Appellant-Petitioner's (hereinafter "Appellant") judgment and sentence was
affirmed in an unpublished opinion by the Fourteenth Court of Appeals, Houston, Texas,
on April 09, 2015, Appellant was advised by counsel his appeal had been affirmed by
USPS mail on or about April 14, 2014, making the PDR due to be filed by Saturday, May
1See Ebong v. State, No. 14-14-00070-CR, Affd April 09, 2015 (Tex. App. - Houston 14th Court of
Appeals, aff d April 09, 2015) (unpublished).
09, 2015. However, pursuant to the Texas Rules of Appellate Procedure it would actually
be due on Monday, May 11, 2015. This proceeding followed.
II.
Appellant's First Motion for Extension of Time
Appellant is incarcerated and is proceeding pro se. As a layman of the law,
Appellant is at a distinct disadvantage in proceeding without counsel and as such he must
conduct all his research in the prison unit law library. The law library only affords inmates
two hours a day, five days a week, unless it is closed for federal holidays or security
reasons.
Therefore, due to the complex and diverse issues which are presentable in his PDR,
Appellant must request that the Court grant him an extension of time of forty-five days, up
to and including Thursday, June 25, 2015, in which to prepare a meaningful pleading for
the Court's consideration.
This is Appellant's first request for an extension of time and is not made in order to
harass or vex the Appellee or otherwise delay these proceedings, but only out of necessity.
Wherefore, Appellant respectfully requests that this Honorable Court grant him an
extension of time in which to file his pro se PDR, up to and including Thursday, June 25,
2015.
SIGNED on this the 6th day of May 06 2015.
Respectfully submitted,
long Ewbng,Appellant, Pro se
)CJ#01908828
Polunsky Unit
3872 FM 350 South
Livingston, Texas 77351-8580
CERTIFICATE OF SERVICE
I, Iniubong Ebong, TDCJ-CID#01908828, Appellant, pro se, herein certify that a
true and correct copy of the foregoing instrument was sent to the Appellee, by placing
same, in a U.S. mail box, first-class, postage paid, addressed to:
Devon Anderson
Harris County District Attorney
1201 Franklin Street, Suite 600
Houston, Texas 77002-1923
SIGNED on this the 6th day of May 2015.