Pierce, Joseph Michael
Pierce, Joseph Michael
Opinion
PD-0651-15 IN THE COURT OF CRIMINAL APPEALS COURT OF CRIMINAL APPEALS AUG 13 2015 OF TEXAS
Joseph Michael Pierce, No. Appellant/Petitioner; vs, Appellant's Motion to AttaftfLiEDtfcN Supplement PetitiofiGWT OF CRIMINAL APPEAI s The State of Texas, Discretionary Review c«lo Appellee/Respondent. AUG I3 20s5 Abel Acosta, Clerk TO THE/HONORABLE COURT-OF'CRIMINAL APPEALS OF TEXAS: COMES NOW, Joseph Michael Pierce, by and through himself, pro se, in the above-styled and numbered cause and respectfully moves this Honorable Court to grant his request to attach or supplement his Petition for Discretionary Review and in support thereof would show the following: 1. Appellant has filed a Petition for Discretionary Review with the Court of Criminal Appeals from an appeal of the Twelfth Court of Appeals at Tyler.
The style and appeal number is: Joseph Michael Pierce v. The State of Texas, Appeal No. 12-14-00073-CR.
2. The Appellant moves that, pursuant to Rule 68.10, Texas Rules of Appel late Procedure, this Court allow Appellant to attach the following page that is attached to this motion as Appendix A to the Petition for Discretionary Review, or to allow Appellant to supplment Appendix A as part of his petition.
3. The facts relied upon to show good cause for this request are, as follows: Appellant mistakenly and not-intentionally misplaced the last page of his Appellant's Brief which caused him to not include the page in his original submission of the Petition for Discretionary Review.
WHEREFORE, PREMISES CONSIDERED, the Appellant respectfully requests that this Honorable Court GRANT his request to attach or supplement his petition.
Appellant's Motion to Attach or Supplement PDR - Pgae 1 Respectfully submitted,
t\ir\nrJ) oIDiO^ Joseph mchael Pierce #01919200 Stiles Unit 3060 FM 3514 Beaumont, Texas 77705
CERTIFICATE OF SERVICE I, Joseph Michael Pierce, certify that:a true and correct copy of the foregoing motion has been mailed, U.S. Mail, postage prepaid, to the Smith County Criminal District Attorney's Office, 100 North Broadway, 4th Floor, Tyler, Texas 75702, and to the State Prosecuting Attoney, P.O. Box 12405, Austin, Texas 78711, on this the $% day of July, 2015.
chael Pierce
VERIFICATION OR INMATE DECLARATION I, Joseph Michael Pierce, TDCJ-CID #01919200, DOB 08-09-1978, being pres ently incarcerated in the Stiles Unit of the Texas Department of Criminal Justice, Institutional Division, Beaumont, Jefferson County, Texas, declare (certify, verify, or state) under penalty of perjury that I have read the above and foregoing motion, that the facts contained herein are trueeand correct, and that this motion is made in good faith.
EXECUTED , this the plP day of July, 2015. f^i-du^H \U!MA~ chael Pierce
Appellant's Motion to Attach or Supplement PDR - Page 2 APPENDIX A: LAST PAGE OF APPELLANT'S BRIEF
Appellant's Motion to Attach or Supplement PDR - Page 3 CERTIFICATE OF SERVICE , Atrue and correct copy of the foregoing Brief of the Appellant has been forwarded to counsel for the State by electronic filing on this the 10th day of September, 2014.
/s/ James Huggler James W. Huggler, Jr.
Attorney for the State: Mr. Michael West Smith County Criminal District Attorney's Office N. Broadway, 4th Floor Tyler, Texas 75702
CERTIFICATE OF COMPLIANCE I certify that this Brief complies with Tex. R. App. P. 9.4, specifically using 14 point Century font and contains 4,113 words as counted by Corel WordPerfect version x5. /s/ James Huggler James W. Huggler, Jr.
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