Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 12/10/2015 4:23:34 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00628-Cr FIRST COURT OF APPEALS HOUSTON, TEXAS 12/10/2015 4:23:34 PM CHRISTOPHER PRINE CLERK No. 01-15-00628-CR In the

Court of Appeals For the

First District of Texas At Houston

 No. 1330029

In the 183 rd District Court Of Harris County, Texas  DARRELL D. BROUSSARD Appellant

V. THE STATE OF TEXAS Appellee

 STATE’S SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF

 TO THE HONORABLE COURT OF APPEALS:

THE STATE OF TEXAS, pursuant to T EX . R. A PP . P. 2 & 10.5, moves for an

extension of time in which to file its appellate brief and in its motion, would show

the Court the following:

1. The State charged the appellant with capital murder by causing the death of

Ahmad Adnan Issaoui while in the course of committing or attempting to

commit a robbery, and the jury found the appellant guilty (CR – 295; 6 RR

34-35). The trial court sentenced him in accordance with the jury’s verdict

to life without the possibility of parole in the Texas Department of Criminal

Justice, Institutional Division (CR – 298-99; 6 RR 36-37). The appellant

gave timely notice of appeal, and the trial court certified that he had the

right to appeal (CR – 301-2; 6 RR 38). The State’s brief is due on December

10, 2015. This is the State’s second request for an extension. The following

facts are relied upon to show good cause for an extension of time to allow

the State to file its brief:

a. The record in this case is over sixty-two megabytes in length split over

eight volumes. The appellant brings four points of error. The undersigned

attorney has read the record and is currently working to address the

appellant’s claims.

b. The undersigned attorney was involved in completing the following

written appellate projects since the appellant filed his brief:

(1) Alfredo Lara v. The State of Texas

01-15-00472-CR

Brief Filed September 24, 2015

(2) Tyran Riley v. The State of Texas

14-15-00081-CR

Brief Filed October 6, 2015

(3) Christian A. Norris v. The State of Texas

01-15-00484-CR, 01-15-00485-CR

Brief Filed October 13, 2015

(4) Juan Jose Quintero v. The State of Texas

14-15-00252-CR

Brief Filed October 27, 2015

(5) Edgar Gutierrez v. The State of Texas

01-15-00490-CR

Brief Filed November 12, 2015

(6) Rodney Sewell v. The State of Texas

14-15-00216-219-CR

Brief Filed November 23, 2015

(7) Miguel Gomez v. The State of Texas

01-15-00179-CR

Brief Due December 14, 2015

(8) Corey Douglas-Myers v. The State of Texas

01-15-00610-CR

Brief Due December 21, 2015

(9) Oscar Rivera v. The State of Texas

01-15-00239-240-CR

Brief Due December 22, 2015

(10) Sandra Berry v. The State of Texas

14-15-00398-00400-CR

Brief Due December 31, 2015

c. The undersigned attorney also had oral argument in the

Fourteenth Court of Appeals on Thursday, October 29 regarding

Odel Allen v. The State of Texas , 14-14-00708-CR.

d. The undersigned attorney also had oral argument in the

Fourteenth Court of Appeals on Tuesday, November 10 regarding

Larry Torres v. The State of Texas , 14-15-00155-158-CR.

Consequently, the undersigned attorney has been unable to complete

the State’s reply brief in this case in the time permitted despite due

diligence, and the requested extension of time is necessary to permit

the undersigned attorney to adequately investigate, complete, and file

the State’s appellate brief for this cause. The State’s motion is not for

purposes of delay, but so that justice may be done.

WHEREFORE, the State prays that this Court will grant a two week extension of

time for the undersigned attorney to complete and file the State’s appellate brief in

this case.

Respectfully submitted, /s/ Katie Davis K ATIE D AVIS Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002-1923 *4 (713) 755-5826 Davis_Katie@dao.hctx.net TBC No. 24070242 *5 CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing instrument will be served by

efile.txcourts.gov to:

Thomas J. Lewis

1602 Washington Ave.

Houston, TX 77007

Tjlaw2@comcast.net

/s/ Katie Davis K ATIE D AVIS Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002-1923 (713) 755-5826 Davis_Katie@dao.hctx.net TBC No. 24070242 Date: December 10, 2015