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FIFTH COURT OF APPEALS 

05-15-00414-CR 

05-15-00415-CR 

Emajin Trevon Jackson, Appellant 

v. 

State of Texas, Appellee 

On Appeal from Criminal District Court No. 6 

Dallas County, Texas 

No. F14-58177 and F14-58178 

Motion to Extend Time to File 

Appellant’s Brief 

 

Michael Mowla 

445 E. FM 1382 No. 3-718 

Cedar Hill, Texas 75104 

Phone: 972-795-2401 

Fax: 972-692-6636 

michael@mowlalaw.com 

Texas Bar No. 24048680 

Attorney for Appellant 

 

ACCEPTED

05-15-00414-CR

FIFTH COURT OF APPEALS

DALLAS, TEXAS

6/22/2015 12:00:00 AM

LISA MATZ

CLERK

 FILED IN 5th COURT OF APPEALS DALLAS, TEXAS 6/21/2015 9:16:40 PM LISA MATZ Clerk
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To the Honorable Justices of the Court of Appeals: 

 Appellant Emajin Trevon Jackson files this motion for extension of time to 

file the Appellant’s Brief moves for an extension of time to file the Appellant’s 

Brief [See Tex. Rule App. Proc. 10.5(b) and 38.6(c)]: 

1. This case is on appeal from Criminal District Court No. 6 of Dallas 

County, Texas. 

2. The cases below are styled the State of Texas v. Emajin Trevon 

Jackson, and are numbered F14-58177 and F14-58178. 

3. On March 25, 2015, sentence was imposed in open court. 

4. Appellant was convicted of Aggravated Robbery with a Deadly 

Weapon in 05-15-00414-CR (F14-58177) and Evading Arrest in 05-15-00414-CR 

(F14-58178). 

5. Appellant is presently incarcerated. 

6. The reporter’s record was filed on June 11, 2015. 

7. The clerk’s record was filed on May 26, 2015. 

8. The Appellant’s Brief is due on July 11, 2015. 

9. Appellant requests an extension of time of 30 days from the present 

due date to file the Appellant’s Brief, i.e., until August 10, 2015. 

10. No previous extension to file the Appellant’s Brief has been filed. 

11. Appellant relies on the following facts as good cause for the requested 
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extension: Attorney for Appellant just completed a reply brief in Esparza v. 

Stephens, 4-14-CV-0694, Eastern District of Texas. 

12. Further, Attorney for Appellant has the following briefs, petitions for 

discretionary review, or other pleadings due soon: 

 Murray v. Texas, petition for writ of certiorari due on July 14, 2015 in 

the Supreme Court of the United States. 

 State v. Hill III, PD-0019-15, PD-0020-15, PD-0021-15, and PD0022-15, brief due on July 10, 2015 in the Court of Criminal Appeals. 

 Garmon v. State, PD-0596-15, petition for discretionary review due 

on July 13, 2015 in the Court of Criminal Appeals. 

 Shortt v. State, PD-0597-15, petition for discretionary review due on 

July 13, 2015 in the Court of Criminal Appeals. 

 Zimmerman v. Cutler, et al, 15-50424, appellant’s brief due on July 

21, 2015 in the Fifth Circuit. 

13. In addition, Attorney for Appellant continues work on a federal

habeas corpus death penalty case, Jones v. Stephens, 4:05-CV-638-Y. 

14. Further, Attorney for Appellant also continues work on a state habeas 

corpus death penalty case, Ex parte Thomas, F86-85539, in the 194th Judicial 

District Court. 

15. Finally, Attorney for Appellant continues work on several habeas 

cases involving the underlying issue in Miller v. Alabama, 132 S.Ct. 2455 (2012). 

16. Attorney for Appellant has a responsibility to Appellant to provide 
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Appellant with the effective assistance of appellate counsel, see Evitts v. Lucey, 

469 U.S. 387, 392 (1985), and Attorney for Appellant believes that that the 

additional time is necessary to provide such effective appellate counsel. 

17. Attorney for Appellant thus requests the extension so that he may 

properly prepare the Appellant’s Brief in accordance with Attorney for Appellant’s 

standards and to provide Appellant the effective assistance of appellate counsel. 

18. This Motion is not filed for purposes of delay, but so that justice may 

be served. 

Prayer 

Appellant prays that this motion for extension of time to file the Appellant’s 

Brief be granted. 

 Respectfully submitted, 

Michael Mowla 

445 E. FM 1382 No. 3-718 

Cedar Hill, Texas 75104 

Phone: 972-795-2401 

Fax: 972-692-6636 

Email: michael@mowlalaw.com

Texas Bar No. 24048680 

Attorney for Appellant 

/s/ Michael Mowla 

Michael Mowla
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Certificate of Service 

I certify that on June 21, 2015, a true and correct copy of this document was served 

by email on the District Attorney’s Office, Dallas County, Appellate Division to 

Lori Ordiway at lori.ordiway@dallascounty.org and Lisa Smith at 

lisa.smith@dallascounty.org. 

 /s/ Michael Mowla 

Michael Mowla