PD-0019-15, PD-0020-15, PD-0021-15 & PD-0022-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 1/5/2015 12:00:00 AM
Accepted 1/12/2015 6:28:34 PM
ABEL ACOSTA
COURT OF CRIMINAL APPEALS CLERK
PD-_______-15
0019
PD-_______-15
0020
JANUARY 12, 2015
PD-_______-15
0021
PD-_______-15
0022
State of Texas, Appellant,
v.
Albert G. Hill, III, Appellee.
On Discretionary Review from
No. 05-13-00421-CR, 05-13-00423-CR
05-13-00424-CR, and 05-13-00425-CR
Fifth Court of Appeals, Dallas
On Appeal from No. F11-00180, F11-00182,
F11-00183, and F11-00191
204th Judicial District Court, Dallas County
Motion to Extend Time to File
Petition for Discretionary Review
Michael Mowla
445 E. FM 1382 #3-718
Cedar Hill, Texas 75104
Phone: 972-795-2401
Fax: 972-692-6636
michael@mowlalaw.com
Texas Bar No. 24048680
Attorney for Appellee
To the Honorable Judges of the Court of Criminal Appeals:
Appellee Albert G. Hill, III moves for an extension of time of 30 days to file
a petition for discretionary review:
1. On December 29, 2014, in State v. Hill, 05-13-00421-CR, 05-13-
00423-CR, 05-13-00424-CR, and 05-13-00425-CR, 2014 Tex. App. LEXIS 13835
(Tex. App. Dallas, December 29, 2014), the Court of Appeals reversed the
judgment and order of the 204th Judicial District Court in which due to
prosecutorial misconduct, the trial court dismissed the indictments against
Appellee.
2. The petition for discretionary review is due on January 28, 2015.
3. For good cause, Appellee asks for an extension of 30 days until
February 27, 2015 to file the petition for discretionary review.
4. No previous extension to file the petition for discretionary review has
been filed.
5. Appellee relies on the following facts as good cause for the requested
extension: undersigned counsel Michael Mowla just completed an Appellant’s
Brief in Little v. State, 05-14-00697-CR, Fifth Court of Appeals.
6. Further, Mowla has the following briefs, petitions for discretionary
review, or other pleadings due soon:
Petition for Writ of Certiorari in Victorik v. Texas, Supreme Court,
due on January 9, 2015.
Page 2 of 4
Petition for Discretionary Review in Johnson v. State, PD-1542-14,
due on January 19, 2015.
Response to Motion for Summary Judgment in Burress v. Blake, et al,
4-14-cv-00035-RAS-DDB, Eastern District of Texas, due on January
20, 2015.
Appellant’s Brief in Von Tungeln v. State, 10-14-00329-CR, Tenth
Court of Appeals, due on January 20, 2015.
Petition for Discretionary Review in Thompson v. State, PD-1591-14,
due on January 30, 2015.
Reply Brief due in Jones v. Stephens, 4:05-CV-00638-Y, Northern
District of Texas (death penalty case), due on February 5, 2015.
Appellant’s Brief due in Williams v. State, 05-14-01481-CR and 05-
14-01482-CR, Fifth Court of Appeals, due on February 8, 2015.
Appellant’s Brief due in King v. State, 05-14-01138-CR, Fifth Court
of Appeals, due on February 21, 2015.
7. In addition, Mowla continues to work on a federal habeas corpus
death penalty case, Jones v. Stephens, 4:05-CV-638-Y, and is presently working on
the Reply in this case, due on February 5, 2015.
8. Mowla also continues to work on several habeas cases involving the
underlying issue in Miller v. Alabama, 132 S.Ct. 2455 (2012).
9. This Motion is not filed for purposes of delay, but so that justice may
be served.
Page 3 of 4
Prayer
Appellee prays that this Court grant this motion for an extension of time to
file a petition for discretionary review.
Respectfully submitted,
Michael Mowla
445 E. FM 1382 #3-718
Cedar Hill, Texas 75104
Phone: 972-795-2401
Fax: 972-692-6636
michael@mowlalaw.com
Texas Bar No. 24048680
Attorney for Appellee
/s/ Michael Mowla
By: Michael Mowla
Certificate of Service
I certify that on January 3, 2015, a true and correct copy of this document
was served on Michael Casillas and Lisa Smith of the District Attorney’s Office,
Dallas County, Appellate Division, by email to michael.casillas@dallascounty.org
and to lisa.smith@dallascounty.org, Charles “Chad” Baruch, special prosecutor,
via email to baruchesq@aol.com, and on Lisa McMinn, the State Prosecuting
Attorney, by email to Lisa.McMinn@spa.texas.gov, and John Messinger, Assistant
State Prosecuting Attorney, by email to john.messinger@spa.state.tx.us. See Tex.
Rule App. Proc. 9.5 (2015) and 68.11 (2015).
/s/ Michael Mowla
By: Michael Mowla
Page 4 of 4