ACCEPTED
01-15-00074-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
8/14/2015 11:55:15 AM
CHRISTOPHER PRINE
CLERK
No. 01-15-00074-CR
In the FILED IN
1st COURT OF APPEALS
Court of Appeals HOUSTON, TEXAS
For the 8/14/2015 11:55:15 AM
First District of Texas CHRISTOPHER A. PRINE
Clerk
At Houston
♦
No. 1256403
In the 337th District Court
Of Harris County, Texas
♦
JUDIST LAMOND BROUSSARD
Appellant
v.
THE STATE OF TEXAS
Appellee
♦
STATE’S FIRST MOTION FOR EXTENSION
OF TIME TO FILE BRIEF
♦
To the Honorable Court of Appeals:
The State of Texas, pursuant to TEX. R. APP. P. 2 & 10.5, moves for an
extension of time in which to file its appellate brief. The following facts are
relevant:
1. The appellant was indicted for capital murder. (CR 15). The appellant
pleaded not guilty, but a jury found him guilty as charged. (CR 115,
117). Because the State did not seek the death penalty, the trial court
sentenced the appellant to confinement for life, without the
possibility of parole. (CR 117). The trial court certified the appellant’s
right of appeal, and the appellant filed a timely notice of appeal. (CR
116, 120).
2. The State’s brief is due on August 14, 2015. The State requests a 45-
day extension of time in which to file its brief.
3. This is the State’s first request for extension.
4. 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 undersigned attorney was assigned this case on August 3,
2015. Since then, he has worked on the following matters:
1. Marcus Jamez Lewis
14-14-00779-CR
Brief filed August 5, 2015
2. Hugo Steve Ramirez
No. 14-15-00323-CR
Case abated on July 21, 2015, with ongoing proceedings
b. The undersigned attorney has been ill and was unable to work
on August 12 and 13.
c. The undersigned attorney has an upcoming pre-paid vacation
that will leave him unable to work on this case during the first
half of September.
WHEREFORE, the State prays that this Court will grant the requested
extension.
Respectfully submitted,
/s/ C.A. Morgan
CLINTON A. MORGAN
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1923
(713) 755-5826
morgan_clinton@dao.hctx.net
TBC No. 24071454
CERTIFICATE OF SERVICE
I certify that I have requested that efile.txcourts.gov electronically serve
a copy of this motion to:
Franklin Bynum
fgb@lawfgb.com
/s/ C.A. Morgan
CLINTON A. MORGAN
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1923
(713) 755-5826
morgan_clinton@dao.hctx.net
TBC No. 24071454
Date: August 14, 2015
Judist Lamond Broussard v. State
Combined Opinion