Lewis, Harlem Harold, Iii

Court of Appeals of Texas·Decided November 2, 2015·No. AP-77,045·Published

Opinion

FILED IN AP-77,045 COURT OF CRIMINAL APPEALS COURT OF CRIMINAL APPEALS AUSTIN, TEXAS October 28, 2015 Transmitted 10/28/2015 2:04:24 PM Accepted 10/28/2015 2:28:36 PM ABELACOSTA, CLERK ABEL ACOSTA No. AP-77,045 CLERK

HARLEM HAROLD LEWIS, HI § IN THE COURT § § OF CRIMINAL APPEALS § THE STATE OF TEXAS § AUSTIN, TEXAS

FINAL MOTION FOR EXTENSION OF TIME

COMES NOW, appellant, by and through his attorney of record, Gerald E. Bourque, and in

accordance with Rule 10.5(b) of The Texas Rules of Appellate Procedure, hereby requests an

extension of time in which to file his Brief and would respectfully show:

1. Name of Trial Court: 351st District Court

2. Trial Court Style: 1428102, The State of Texas v. HARLEM HAROLD LEWIS, III

3. Offense: Capital Murder

4. Punishment assessed: Death

5. Present Filing Deadline: November 6, 2015

6. Length of Extension Requested: 60 days

7. Number of Previous Extensions: Two by current counsel

8. Good Cause for this Extension is as follows: This is a capital murder case and counsel was not the trial counsel. The record is voluminous and the case is complex. Counsel was appointed to replace prior appellate counsel and has been studying the entire record in order to identify potential issues, conduct the necessary research, and complete the brief for appellant, which has been ongoing. The voluminous record requires an inordinate amount of time in order to complete these tasks. These tasks are necessary to provide the effective assistance of counsel. Counsel has made considerable progress and does not anticipate requesting any further extensions in this complex case. WHEREFORE, PREMISES CONSIDERED, appellant respectfully files this motion before

the expiration of the filing deadline, and prays for the requested extension.

Respectfully submitted, /s/Gerald E. Bourque GERALD E. BOURQUE Appointed Counsel for Appellant Attorney at Law 24 Waterway Ave., Suite 660 The Woodlands, TX 77380 . (281)379-6901 FAX: (832) 813-0321 TBL #02716500

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing Motion was served upon the

counsel for the State by U.S. Mail on the date of filing hereof.

/s/Gerald E. Bourque GERALD E. BOURQUE

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