PD-1091-15 CAUSE NO. ______________________ IN THE COURT OF CRIMINAL APPEALS FOR THE STATE OF TEXAS ***** BEDROS NOBAR MINASSIAN, Petitioner / Appellant v. THE STATE OF TEXAS, Respondent / Appellee ***** 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. Jackson Street, Suite 330 Dallas, Texas 75202 Telephone: (214) 871-4900 Facsimile: (214) 871-7543 Email: [email protected] COUNSEL FOR August 24, 2015 PETITIONER/APPELLANT BEDROS NOBAR MINASSIAN 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.

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 _________________________________ TOM PAPPAS TEXAS BAR CARD NO.15455300 Jackson Street, Suite 330 Dallas, Texas 75202 Telephone: (214) 871-4900 Facsimile: (214) 871-7543 Email: [email protected] 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 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 _________________________________ TOM PAPPAS