Judist Lamond Broussard v. State

Opinion

ACCEPTED

01-15-00074-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS 6/24/2015 8:44:11 PM CHRISTOPHER PRINE

CLERK

01-15-00074-CR FILED IN 1st COURT OF APPEALS

In the Court of Appeals HOUSTON, TEXAS for the First District of Texas 6/24/2015 8:44:11 PM CHRISTOPHER A. PRINE

Clerk

Judist Broussard,

Appellant

v.

The State of Texas,

Appellee

Third and Final Motion to Extend Time to File Brief

Judist Broussard moves, under Rules 10.1 and 10.5(b) of the Texas Rules of Appellate Procedure, to extend the deadline for filing his brief.

The current deadline is June 24, 2015. This is Appellant’s third motion to extend time to file his brief. No further extensions will be filed. Only 20 additional days are needed to complete the brief.

Exceptional circumstances support granting one final extension. Counsel filed a brief in this Court two days ago in another appeal from a conviction for murder—Andre Thompson v. State, 01-14- 00862-CR. That brief was filed on an expedited schedule, in which no extensions would be granted, because it came after appointed counsel filed an Anders brief.

Counsel had planned to file the brief in this case by the current due date, but was not able to do so. This case is an appeal of a well-litigated capital-murder trial, in which defense counsel

2

raised several serious constitutional issues. A small amount of additional time is necessary to fully research and brief those issues.

In addition to this case, counsel has been occupied with preparing for two hearings for motions for new trial: State v. Bobby Smith in Liberty County and State v. Marcos Iturbe in Harris County; and the appeal in Pete Rodriguez v. State, 01-15-00135-CR.

Appellant prays that the Court grant the motion and extend the deadline for filing his brief for 20 days from the existing deadline, to July 14, 2015.

Certificate of Compliance

The word-processing software used to write this motion reports its length as 345 words.

Certificate of Service

I provided this document to the State by electronic service to curry_alan@dao.hctx.net simultaneously with electronic filing.

Respectfully,

/s/ Franklin Bynum

Bynum Law Office PLLC Franklin Bynum 2814 Hamilton Street Texas Bar Number 24069451 Houston, Texas 77004 fgb@lawfgb.com (713) 343-8844