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                                             twel'fth court of appeal's

Oelanda        Letrepg    Player                   MO.    12-1F-00259-          CI/


 l/s                                                                Trial       Cour':                                         -14
                                                                                          12ttiCcx*t o' Appeals ;<srict

The    State     of   Texas


                                     MOTION    FDR       EXTENSION       OF    TIME

         Plaintiff has          brought before this Court a suit                          Tor     his      release              from


 pursuant to 11.07 hbabeas corpus and a Oarnishment suit for Plaintiff's

 Plaintiff will          need    to    seek a       extension       of    time      in   order      to      Amend his

suit and file a 11.07 habeas corpus application.                                      Plaintiff -Applicant

 needs    to    obtain    forms       and to       have    access    to       the   Court's       by     means            of

being afforded time to go to the law library in order to review the law

 necessary to file the Amendments and suit's filed already with the

 Court.


         Plaintiff-Applicant has deadlines for filing these items set as

 November 30, 2015, the information needed to amend to show jurisdiction

 of this court, and needs law library time to complete these tasks and

 seeks    an    extension       of    time    of    60    days.

          Plaintiff has not had time since the                            month of October order of this

Court as the          Plaintiff will show this Court the                            whole month of October

he was on "L'ock-down" confined to his cell due to "security measures of

the    wynne Unit's (6) Month annual cell searches and shack-down of all
inmate-offenders on the Unit,                      which denied Plaint iff-App1icant of access

to the Court by denying access to the law library and ability of going
to commissary to purchase stamps to mail out any legal correspondence to
the Court's which also caused Plaintiff of the ability to file any type
of correspondence to the Court's.
       Plaintiff was also impended by the official's of the Wynne Unit by
keeping Plaintiff locked-up, in Plaintiff's cell after it was completed,
  Page   2.


 after the searches were completed by again locking Plaintiff down du to
 the "Electricity" going out for another two weeks denying             Plaintiff       of
lights to be able to see anything or being able to see good enough write
any Iwgal matters because Plaintiff didn't have lights to see good enough
to do any legal research in these matters. Plaintiff was placed under these
conditions for a total of four weeks without even being able to send out
mail to anyone because the mailroom officer's were not picking mail out
going up from the cells where Plaintiff was confined. Therefore Plaintiff
seek (60)     days extension. To comply with the Court orders.
         Plaintiff will suffer a manifest injustice, for a extension of time
if not granted one. See Holland vs. Florida, 560 U.S. 631, 645 (2010).
     Plaintiff contends he is entitlted to relief in these matters.
                                               Respectfully Submitted

                                               && A a A -irjPj>/jLlhoJ
                                               Delanda Letregg Pluayer (—^
                                               TDC3-ID#1955184
                                               Wynne    Unit
                                              810    F.M.     2821
                                              Huntsville,          Texas    77349

     Plaintiff Delanda Letregg Player TDC3-ID* 1955184, being presently
incarcerated at the Wynne Unit of the Texas Department of Criminal justice-
Institutional Division, in Walker County, Texas, declare under penalty of
perjury that the foregoing is true and correct. Executed on this c^J>~Day of
/V CQ^)y^yy/\-Py^J) 2015.

                                             Delanda Letregg Player                 (J ~ I
                                             TDCj-ID#1955184
                                             Wynne     Unit
                                             810   F.M.     2821
                                             Huntsville,       Texas       77349
