Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 6/24/2015 8:44:11 PM CHRISTOPHER A. PRINE Clerk *1 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 In the Court of Appeals for the First District of Texas 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 ap-
pointed 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
raised several serious constitutional issues. A small amount of ad-
ditional 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
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