PD-0983-15
PD-0983-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 7/30/2015 3:41:06 PM
July 30, 2015
Accepted 7/30/2015 4:37:04 PM
PD ABEL ACOSTA
NO. 02-13-00244-CR CLERK
STATE OF TEXAS § IN THE
VS. § COURT OF
MICHAEL AMOS § CRIMINAL APPEALS
APPELLANT'S MOTION FOR EXTENSION OF TIME
TO FILE PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE COURT OF CRIMINAL APPEALS:
Comes now Appellant, and files this Motion for the Court to extend the time for filing of
Appellant's PDR and shows the Court the following:
1. Appellant was convicted of Cruelty Animal-Torture on Cause Numbers 1322040,
styled "The State of Texas v. Michael Amos in the Criminal District Court No. 4 of Tarrant
County, Texas. Appellant was sentenced to 31 months confinement in the Institutional Division
of the Texas Department of Corrections on May 16, 2013.
2. Appeal was perfected by notice of appeal filed on May 20, 2013. A motion for new
trial was filed. Appellant’s appeal was affirmed by the Second Court of Appeals on July 02,
2015.
3. Appellant's PDR is due in the Court of Criminal Appeals on July 31, 2015.
4. Appellant seeks an extension of sixty days within which to file the PDR. There has
been one previous extensions of time requested and granted with regard to the filing of
appellant's PDR. The submission date in this case is not set. Therefore, this requested extension
would not delay submission.
5. This extension is not requested for purposes of delay but rather to adequately brief the
legal issues for appeal and insure justice is done.
6. The Appellant’s initial Appeal was affirmed by the Court of Appeals on July 02, 2015.
Since this date, counsel for Appellant has been in trial or preparing for trial on major cases,
Styled “The State of Texas vs. Camron Deshaun Butler” in Criminal District Court No. 4,
which is a Murder. “The State of Texas vs. Arnulfo Mauricio Jr.” in the 213th Judicial District
Court, Engaging Organized Crime, Burglary of a Habitation, Manuf Cont Sub 0/400G-PG1, and
aggravated robbery ; styled “The State of Texas vs. Donald R. Bailey in the Criminal District
Court 1 is a Arson Damage Habit/ Worshi.
These cases were or are all contested trials and Counsel for Appellant is either preparing
them for trial or actually in trial, as well as handling many other cases. It has not been possible
for Counsel to complete the PDR due to this large number of court settings and serious cases
which went or are going to lengthy jury trials.
Appellant’s attorney apologies to the Court for requesting an extension of time; however,
counsel’s unexpected trial schedule has prohibited counsel’s ability to prepare the PDR.
An extension of sixty days will be necessary and adequate to allow the completion
of the PDR.
WHEREFORE, ALL PREMISES CONSIDERED, Appellant prays that the Court
grant an extension of sixty days to file the PDR.
Respectfully submitted,
Lisa Mullen
_________________________
/s/Lisa Mullen
Attorney at Law
3149 Lackland Road, Suite 102
Fort Worth, Texas 76116
817-332-8900
Fax: 817-332-8904
SBN: 03254375
lisa@mullenlawoffice.com
CERTIFICATE OF SERVICE
This is to certify that on July 30, 2015 a true and correct copy of the above and foregoing
document was served with the Tarrant County District Attorney's Office, 401 West Belknap, Fort
Worth, Texas, 76196, by U.S. Postal Mail.
Lisa Mullen
________________________________
/s/ Lisa Mullen
Attorney at Law
CERTIFICATE OF CONFERENCE
I, Lisa Mullen, certify that I have conferred with Counsel for the State and they do not
oppose the granting of Appellant’s Motion for Extension of Time to file Appellant’s PDR.
Lisa Mullen
________________________
/s/ Lisa Mullen
AFFIDAVIT
THE STATE OF TEXAS
COUNTY OF TARRANT
I, Lisa Mullen, Attorney at Law, being duly sworn, on my oath say that the facts stated in
the foregoing motion are true and correct to the best of my knowledge.
Lisa Mullen
______________________________
/s/Lisa Mullen
Attorney at Law
State Bar Number: 03254375
lisa@mullenlawoffice.com
Subscribed to and sworn before me on this date: July 30, 2015
Nancy Mata Martinez
_____________________________
/s/Nancy Mata Martinez
Notary Public for The State
My Commission expires: August 31, 2016