COMES NOW, MAHMOUD AFHAMI, Appellant, and moves for an extension of fourteen (14) days in which to file his Petition for Discretionary Review, until and includingJune 1, 2015, and would further show as follows:

A. On March 17, 2015, in cause number 14-13-01013-CR, styled "Mahmoud

Afhami vs. The State of Texas," the Fourteenth Court of Appeals affirmed the Appellant's conviction for terroristic threat against a member of Appellant's family. No motion for rehearing was filed. The deadline for filing the Petition for Discretionary Review in this cause is

B

currently Monday, May 18, 2015. C. A request is hereby made for a final extension of time to file the Appellant's

Brief, until and including Monday, June 1, 2015. D: The undersigned attorney, Bob Wicoff, has been unusually busy with other

matters which have kept him from completing the PDR by the current deadline, including, but not limited to, the following:

GERARDO TAPIA-LOPEZ VS. THE STATE OF TEXAS; No. 01-14- 01016-CR; Appellant's brief due on May 20, 2015;

Additionally, the undersigned serves on the Texas Forensic Science Commission Hair Microscopy Panel, as part of a team reviewing hundreds of cases involving possible errors in expert testimony.

Further, the undersigned is the chief of the appellate division of the Harris County Public Defender's Office, which is extraordinarily busy at the current time.

One lawyer in the division (Angela Cameron) has just returned from six weeks' absence due to a prolonged illness and another (Nicolas Hughes) has been unable to handle his usual docket of direct appeals for several months now due to an influx of nearly 400 post-conviction writs which stem from drug convictions, followed by laboratory reports indicating no controlled substance to support the conviction.

The undersigned, though not appearing as attorney of record on either of the above attorney's cases, has been shouldering their workload. Additionally, the undersigned is currently handing nearly a dozen Chapter 64 cases, and is the only attorney in the Harris County Public Defender's Office who handles those cases.

D One previous extension has been granted. If this, unexpected extension request is granted, no further extensions are expected to be needed.

Respectfully submitted, ALEXANDER BUNIN Chief Public Defender Harris County Texas /s/ Bob Wicoff BOB WICOFF 1201 Franklin, Thirteenth Floor Houston Texas 77002 (713) 274-6781 TBA No. 21422700 Bob.wicoff@pdo.hctx.net CERTIFICATE OF SERVICE A true copy of this motion has been served electronically on the Harris County District Attorney's Office Appellate Division on the 18th day of May, 2015.

/s/ Bob Wicoff BOB WICOFF