Ahshan, Ex Parte Muhammad Saadan

• Court: Court of Appeals of Texas
• Decided: December 7, 2015
• Docket: PD-1585-15
• Status: Published

Opinion

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

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