PD-0399-15
PD-0399-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
April 15, 2015 Transmitted 4/7/2015 1:35:20 PM
Accepted 4/15/2015 10:51:09 AM
PD- ABEL ACOSTA
CLERK
MAHMOUD AFHAMI X IN THE COURT OF CRIMINAL APPEALS
X
X
VS. X
X
X
THE STATE OF TEXAS X OF THE STATE OF TEXAS
MOTION FOR EXTENSION OF TIME
TO FILE PETITION FOR DISCRETIONARY REVIEW
COMES NOW, MAHMOUD AFHAMI, Appellant, and moves for an
extension of thirty (30) days in which to file his Petition for Discretionary Review,
until and including May 18, 2015, and would further show as follows:
A. On March 17, 2015, in cause number 14-13-01013-CR, styled “Mahmoud
Afhami vs. The State of Texas,” the Fourteenth Court of Appeals affirmed the
Appellant’s conviction for terroristic threat against a member of Appellant’s
family. No motion for rehearing was filed.
B. The deadline for filing the Petition for Discretionary Review in this cause is
currently Thursday, April 16, 2015.
C. A request is hereby made for an extension of time to file the Appellant’s Brief,
until and including Monday, May 18, 2015.
D. The undersigned attorney, Bob Wicoff, has been unusually busy with other
matters which have kept him from completing the PDR by the current
deadline, including, but not limited to, the following:
FEANYICHI UVUKANSI VS. THE STATE OF TEXAS; No. 01-14-00527-
CR; Appellant’s brief filed on March 9, 2015 (capital murder);
GRISELDA AZA VS. THE STATE OF TEXAS; Nos. 14-14-00241-CR and
14-14-00242-CR; Appellant’s brief filed March 11, 2015;
RICHARD SCOTT VS. THE STATE OF TEXAS; No. 14-14-00726-CR;
Appellant’s brief filed March 18, 2015;
NORMA SANCHEZ VS. THE STATE OF TEXAS; No. 14-14-00780-CR;
Appellant’s brief filed March 19, 2015;
JAMIE IBARRA VS. THE STATE OF TEXAS; No. 14-13-00337-CR;
Appellant’s PDR filed on April 1, 2015;
Additionally, the undersigned serves on the Texas Forensic Science
Commission Hair Microscopy Panel, as part of a team reviewing hundreds of cases
involving possible errors in expert testimony.
D. No previous extensions have been requested. If this extension request is
granted, no further extensions are expected to be needed.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
/s/ Bob Wicoff__________
BOB WICOFF
1201 Franklin, Thirteenth Floor
Houston Texas 77002
(713) 274-6781
TBA No. 21422700
Bob.wicoff@pdo.hctx.net
CERTIFICATE OF SERVICE
A true copy of this motion has been served electronically on the Harris County
District Attorney’s Office Appellate Division on the 7th day of April, 2015.
/s/_Bob Wicoff_________
BOB WICOFF