FILED IN
AP-77,045
COURT OF CRIMINALAPPEALS COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
August 27, 2015 Transmitted 8/27/2015 3:05:22 PM
Accepted 8/27/2015 4:03:08 PM
ABELACOSTA, CLERK No. AP-77,045 ABEL ACOSTA
CLERK
HARLEM HAROLD LEWIS, III IN THE COURT
V. 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: 1428102, The State of Texas v. Harlem Harold Lewis, III
3. Offense: Capital Murder
4. Punishment assessed: Death
5. Present Filing Deadline: September 7, 2015
6. Length of Extension Requested: 60 days
7. Number of Previous Extensions: One 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
(713)862-7766
FAX: (832) 813-0321
gerald@geraldebourque.com
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