PD-1585-15 PD-1585-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 12/4/2015 5:10:07 PM
Accepted 12/7/2015 2:14:30 PM
ABEL ACOSTA
Cause No.: 01-14-00815-CR CLERK
COURT OF CRIMINAL APPEALS OF TEXAS
MOHAMMAD SAADAN AHSAN
Appellant
v
THE STATE OF TEXAS
Appellee
APPEALED FROM THE 228TH JUDICIAL DISTRICT COURT
228TH JUDICIAL COURT CASE NUMBER: 1336348
COURT OF APPEALS CASE NUMBER: 01-14-00815-CR
FIRST COURT OF APPEALS
MOTION FOR EXTENSION OF TIME
TO FILE PETITION FOR DISCRETIONARY REVIEW
WITH THE TEXAS COURT OF CRIMINAL APPEALS
/s/ Gene P. Tausk___________
Gene P. Tausk
TBN: 24003035
1221 Studewood
Houston, TX 77008
(713) 429-5476
(713) 490-3150 (fax)
gene@tauskvega.com
December 7, 2015
Cause No.: 01-14-00815-CR
COURT OF CRIMINAL APPEALS OF TEXAS
MOHAMMAD SAADAN AHSAN
Appellant
v
THE STATE OF TEXAS
Appellee
APPEALED FROM THE 228TH JUDICIAL DISTRICT COURT
228TH JUDICIAL COURT CASE NUMBER: 1336348
COURT OF APPEALS CASE NUMBER: 01-14-00815-CR
FIRST COURT OF APPEALS
MOTION FOR EXTENSION OF TIME
TO FILE PETITION FOR DISCRETIONARY REVIEW
WITH THE TEXAS COURT OF CRIMINAL APPEALS
TO THE HONORABLE JUSTICES OF THE TEXAS COURT OF CRIMINAL
APPEALS:
COMES NOW Mohammad Saadan Ahsan, your Appellant (“Appellant” or
“Ahsan”) who respectfully asks this Honorable Court for an extension of thirty (30)
days to file a Petition for Discretionary Review with this Honorable Court. Good
cause is needed for this Motion for Extension (“Motion”) and Ahsan would show
this Honorable Court as follows:
I.
This is the first Motion for Extension that is filed by Ahsan.
II.
This case was initially appealed from the 228 th Judicial District Court in
Houston, Harris County, Texas to the 1st Court of Appeals in Houston, Harris
County, Texas. The case number at the 228th Judicial District Court is: 1336348.
The case number from the First Court of Appeals is: 01-14-00815-CR.
III.
The First Court of Appeals rendered judgment on this case on or about
November 17, 2015. This Motion is therefore timely filed.
IV.
There were no motions for rehearing or motions for en banc reconsiderations
filed in this matter.
V.
Good cause exists for this Motion.
First, Ahsan would respectfully point out to this Honorable Court that this is
the holiday season. Ahsan’s undersigned counsel has two children with many
holiday events during this time and for family reasons, these personal matters must
be attended.
In addition, Ahsan’s undersigned counsel has several deadlines to meet during
this month including, but not limited to: (1) response to a Motion for Summary
Judgment that will require a great deal of preparation; (2) a pending case before the
5th Circuit Court of Appeals.
Ahsan’s undersigned counsel would point out to this Honorable Court that the
extra time will allow Your Undersigned Counsel to give the Petition for
Discretionary Review the time and attention that this will demand.
CONCLUSION AND PRAYER
For the above-stated reasons, therefore, Ahsan respectfully asks this
Honorable Court for an additional 30 days to file the Petition for Discretionary
Review.
Respectfully submitted:
/s/ Gene P. Tausk
Gene P. Tausk
TBN: 24003035
1221 Studewood
Houston, TX 77008
(713) 429-5176
(713) 490-3150 (fax)
gene@tauskvega.com
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing was served upon the
Harris County District Attorneys’ Office on December 4, 2015.
/s/ Gene P. Tausk_______________
Gene P. Tausk
CERTIFICATE OF CONFERENCE
I certify that on or about December 4, 2015 I attempted to contact the Harris
County District Attorneys’ Office regarding this matter but was unsuccessful.
/s/ Gene P. Tausk
Gene P. Tausk