Minassian, Bedros Nobar

Opinion

PD-1091-15

CAUSE NO. ______________________

IN THE COURT OF CRIMINAL APPEALS FOR THE STATE OF TEXAS

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BEDROS NOBAR MINASSIAN, Petitioner / Appellant v.

THE STATE OF TEXAS, Respondent / Appellee

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On Petition from a Decision of the Court of Appeals for the Fifth District of Texas, Dallas Division in Cause No. 05-13-00936-CR

MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

TOM PAPPAS

BURLESON PATE & GIBSON, L.L.P.

900 Jackson Street, Suite 330 Dallas, Texas 75202

Telephone: (214) 871-4900 Facsimile: (214) 871-7543 Email: tpappas@bp-g.com

COUNSEL FOR

August 24, 2015 PETITIONER/APPELLANT BEDROS NOBAR MINASSIAN

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TO THE HONORABLE JUDGES OF SAID COURT:

COMES NOW, BEDROS NOBAR MINASSIAN, Petitioner herein, and Appellant before the Court of Appeals for the Fifth District of Texas at Dallas, Texas, and files her Motion to Extend Time to File Petition for Discretionary Review.

I.

On July 16, 2015, the Court of Appeals for the Fifth District of Texas, Dallas Division issued its Judgment and Opinion in Cause 05-13-00936-CR. The Petitioner/Appellant has not filed a motion for rehearing or en banc reconsideration with the Court of Appeals for the Fifth District of Texas, Dallas Division.

II.

The deadline for Petitioner/Appellant to file his Petition for Discretionary Review is August 17, 2015. Counsel needs additional time to work with the Petitioner/Appellant in preparing the Petition for Discretionary Review.

III.

Therefore, the Petitioner/Appellant respectfully requests that this Court pursuant to T.R.App.P. Rule 68.2(c) grant an extension of time to file the Petition for Discretionary Review to September 16, 2015, thirty (30) days after the last day for filing the Petition.

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PRAYER FOR RELIEF

The Petitioner respectfully prays that this Court grant this Motion to Extend Time to File Petition for Discretionary Review to September 16, 2015.

Respectfully submitted,

BURLESON PATE & GIBSON, L.L.P.

/s/ Tom Pappas

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TOM PAPPAS

TEXAS BAR CARD NO.15455300

900 Jackson Street, Suite 330 Dallas, Texas 75202

Telephone: (214) 871-4900 Facsimile: (214) 871-7543 Email: tpappas@bp-g.com

COUNSEL FOR

PETITIONER/APPELLANT

BEDROS NOBAR MINASSIAN

CERTIFICATE OF SERVICE

This will certify that a copy of the foregoing was delivered by placing same in the United States Mail via U.S. First Class mail to the following:

Mr. Michael R. Casillas Ms. Lisa M. McMinn Dallas County District Attorney State Prosecuting Attorney 133 N. Riverfront Blvd., LB 19 P.O. Box 13046 Dallas, Texas 75207 Austin, Texas 78711

DATED the 17th day of August, 2015.

/s/ Tom Pappas

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TOM PAPPAS