In The
  Court of Appeal of the State of California
  In and For the
  THIRD APPELLATE DISTRICT



                                                                                        IN RE:  CASE NO. C030469

   SHASTA COUNTY
 JERRY WAYNE MORGAN                                                      No. 97F9169

                                                                                         REQUEST TIME TO FILE
                                                                                         SUPPLEMENTAL BRIEF
________________________________________/
 
 

 On March 1, 1999, S. LYNNE KLEIN, Attorney at Law, filed an Opening Brief, in the above-entitled case. 

I am requesting additional time to file a Supplemental Brief.  I am on lockdown 24 hours a day, most of the time.  I have no access to law books, or typewriter or any way to prepare this brief.  I request an Invervenor to help me prepare this brief to submit to the Court, in fact my friend Janice D. Crumley has offered to help with this Brief.

Under Johnson v. Avery, 393 U.S. 483 (1969), which states as follows:  MR. JUSTICE DOUGLAS, concurring.

"We think of claims as grist for the mill of the lawyers. But it is becoming abundantly clear that more and more of the effort in ferreting out the basis of claims and the agencies responsible for them and in preparing the almost endless paperwork for their prosecution is work for laymen. There are not enough lawyers to manage or supervise all of these affairs; and much of the basic work done requires no special legal talent. Yet there is a closed-shop philosophy in the legal profession that cuts down drastically active roles for laymen. It was expressed by a New York court in denying an application from the Neighborhood Legal Services for permission to offer a broad legal-aid type of service to indigents:

 . . .That traditional, closed-shop attitude is utterly out of place in the modern world where claims pile high and much of the work of tracing and pursuing them requires the patience and wisdom of a layman rather than the legal skills of a member of the bar.

The plight of a man in prison may in these respects be even more acute than the plight of a person on the outside. He may need collateral proceedings to test the legality of his detention or relief against management [393 U.S. 483, 493] of the parole system or against defective detainers lodged against him which create burdens in the nature of his incarcerated status. He may have grievances of a civil nature against those outside the prison. . ."

I need more time to prepare this Brief, in that it takes up to two weeks for me to receive my mail, and may need more than 30 days additional time.
 

Dated_____________________________  ______________________________
                                                                     JERRY WAYNE MORGAN