Lewis, Harlem Harold, Iii ( 2015 )

FILED IN AP-77,045 COURT OF CRIMINALAPPEALS &PV COURT OF CRIMINAL APPEALS June 4, 2015 4o AUSTIN, TEXAS Transmitted 6/4/2015 1:27:26 PM Accepted 6/4/2015 1:42:14 PM ABEL ACOSTA ABELACOSTA, CLERK NO. AP-77,045 4>C CLERK *< HARLEM HAROLD LEWIS, III IN THE COURT OF CRIMINAL APPEALS THE STATE OF TEXAS AUSTIN, TEXAS 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: Cause No. 1428102, The State of Texas v. HARLEM HAROLD LEWIS, III 3. Offense: Capital Murder 4. Punishment assessed: Death 5. Present Filing Deadline: June 8, 2015 6. Length of Extension Requested: 180 days 7. Number of Previous Extensions: None 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. 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. 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