Ahshan, Ex Parte Muhammad Saadan

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