Safian, Anthony Robert

PD-0323&0324&0325-16 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 9/23/2016 5:33:34 PM Accepted 9/26/2016 9:10:13 AM IN THE COURT OF CRIMINAL APPEALS ABEL ACOSTA OF TEXAS CLERK ANTHONY ROBERT SAFIAN § September 26, 2016 Petitioner, § VS. § NO. PD-0324-16 § THE STATE OF TEXAS § Respondent. § PETITIONER’S MOTION TO EXTEND TIME FOR FILING OF BRIEF ON PETITION FOR DISCRETIONARY REVIEW This motion is brought by ANTHONY ROBERT SAFIAN, Petitioner, who pursuant to rules 38.6 and 68.2( c) of the Texas Rules of Appellate Procedure requests that this Court grant an extension of time for filing of Petitioner’s Brief on Petition for Discretionary Review and in support would show the following: I. Petitioner’s brief is due on September 23, 2016. The time for extension requested is thirty (30) days. II. Because of an unusually heavy caseload consisting of both jury trials as well as other appellate obligations, counsel for Appellant has been unable to complete said brief; as a result of trial preparation and actual trial, counsel for Appellant has been unable to devote a sufficient amount of time to the preparation of said brief. As a result of the aforementioned activities counsel for Appellant, reasonably believes that the brief will be filed with this Court within thirty (30) days of the September 23, 2016, date. III. No previous “Motion to Extend Time for Filing Petitioner’s Brief on Petitioner for Discretionary Review” has been granted. Motion to Extend Time for Filing of Petitioner’s Brief on Petition for Discretionary Review Page 1 of 3 IV. The Appellant is incarcerated. WHEREFORE, PREMISES CONSIDERED, Appellant,ANTHONY ROBERT SAFIAN, prays this Court will grant an extension of thirty (30) days for Appellant to file said brief. Respectfully submitted, /s/ Daniel Collins Daniel Collins TBN: 24071079 Daniel Collins Law 3663 Airport Freeway Fort Worth, Texas 76111 Phone: (682) 444-1004 Fax: (817) 886-2215 E-mail: Daniel@DanielCollinslaw.com Attorney for Petitioner Anthony Robert Safian CERTIFICATE OF CONFERENCE I do hereby certify that a conference was held on September 23, 2016, with the Tarrant County District Attorney’s office, and that office stated that it is not opposed to the granting of the relief requested in this motion. /s/ Daniel Collins Daniel Collins Motion to Extend Time for Filing of Petitioner’s Brief on Petition for Discretionary Review Page 2 of 3 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument has been furnished to counsel for the Appellees listed below pursuant to Rule 9.5(b)(1) of the Texas Rules of Appellate Procedure through the electronic filing manager, as opposing counsel’s email address is on file with the electronic filing manager, on this 23rd day of September , 2015. /s/ Daniel Collins Daniel Collins Debra Windsor Tarrant Co. District Atty’s Office 401 West Belknap Fort Worth, Texas 76196 Motion to Extend Time for Filing of Petitioner’s Brief on Petition for Discretionary Review Page 3 of 3