ACCEPTED
14-15-00526-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
10/14/2015 3:39:37 PM
CHRISTOPHER PRINE
CLERK
IN THE
FOURTEENTH COURT OF APPEALS
OF TEXAS FILED IN
14th COURT OF APPEALS
HOUSTON, TEXAS
VINCENT EDWARD BROUSSARD § CASE NO. 10/14/2015
14-15-00526CR
3:39:37 PM
§ CASE NO. CHRISTOPHER
14-15-00527CR A. PRINE
§ Clerk
VS. § On Appeal From Harris County
§ Cause No. 1444909 &
§ Cause No. 1447644
§ 184TH District Court
THE STATE OF TEXAS §
APPELLANT’S MOTION
TO EXTEND TIME TO FILE APPELLATE BRIEF
Appellant, Vincent Edward Broussard, moves for an extension of time to file his
appellate brief, under TEX. R. APP. P. 10.5(b).
I. TRIAL COURT PROCEEDINGS
On June 4, 2015, a judge sentenced Mr. Broussard to 45 years and 45 years in
the Institutional Division, TDCJ, after guilty pleas to two charges of aggravated
robbery-deadly weapon. Defendant filed notice of appeal on June 4, 2015.
II. PROCEEDINGS IN THIS COURT
The Appellant’s brief was due October 12, 2015. One previous extension has
been requested.
III.
Since the record was completed, counsel has filed a brief in Eric Samuel Tucker
v. State, Cause No. 01-15-00274-CR, and has been working to complete a brief in Mayer
v. State, Cause No. 14-14-01011-CR, which is subject to abatement. Counsel also has
researched and prepared a response to the state’s motion for the juvenile court to waive
jurisdiction after a reversal and remand on appeal in Guerrero v. State, Cause No. 14-
13-00101-CR, for a hearing that ultimately was reset. Counsel also has five other briefs
and one petition for discretionary review this month
IV.
In the exercise of due diligence, counsel was unable to complete the brief by the
deadline, and needs an additional 30 days to file it. This motion is not filed for purposes
of delay, but so that justice may be done.
PRAYER
Appellant respectfully requests that this motion be granted and that the Court
permit an extension of time until November 12, 2015 to file Appellant’s brief.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
/s/ Cheri Duncan
______________________________
CHERI DUNCAN
Assistant Public Defender
Harris County Texas
SBN 06210500
1201 Franklin, 13th Floor
Houston Texas 77002
(713) 368-0016
(713) 368-9278 (Fax)
cheri.duncan@pdo.hctx.net
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Attorney for Appellant,
Vincent Edward Broussard
CERTIFICATE OF SERVICE
I certify that a copy of Appellant’s Motion to Extend Time to File Appellate
Brief was served electronically on the Appellate Division of the Harris County District
Attorney’s Office, 1201 Franklin St, 6th Floor, Houston, TX on October 14, 2015.
/s/ Cheri Duncan
____________________________________
CHERI DUNCAN
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