ACCEPTED
01-15-00393-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
8/3/2015 12:00:00 AM
CHRISTOPHER PRINE
CLERK
No. 01-15-00393-CR
__________________________________________________________________
FILED IN
1st COURT OF APPEALS
IN THE COURT OF APPEALS HOUSTON, TEXAS
FOR THE FIRST DISTRICT OF TEXAS 8/3/2015 10:15:00 AM
AT FORT WORTH CHRISTOPHER A. PRINE
______________________________________________Clerk
CHRISTOPHER ERNEST BRAUGHTON,
Defendant-Appellant,
v.
THE STATE OF TEXAS,
Plaintiff-Appellee.
______________________________________________
On Appeal from the 228th Judicial District Court
Trial Court Case No. 1389139
______________________________________________
DEFENDANT-APPELLANT’S
MOTION FOR EXTENSION
OF TIME TO FILE INITIAL BRIEF
________________________________________________
Robert L. Sirianni, Jr., Esq.
Texas Bar No. 24086378
THE LAW OFFICE OF ROBERT L. SIRIANNI, JR.
201 N. New York Ave. Suite 200
Winter Park, Florida 32789
Tele: 407-388-1900
Fax: 407-622-1511
Robert@brownstonelaw.com
Counsel for Defendant-Appellant
__________________________________________________________________
July 28, 2015
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
COMES NOW, DEFENDANT-APPELLANT CHRISTOPHER
ERNEST BRAUGHTON, through undersigned counsel in the above-styled cause,
and respectfully submits this Motion for Extension of Time to File Initial Brief, and
as grounds would show unto the Court the following:
1. Defendant-Appellant Christopher Ernest Braughton retained the firm
Robert L. Sirianni, Jr. to represent him on appeal.
2. The court reporter’s record was filed on July 9, 2015. The Initial Brief
is therefore due on August 10, 2015.
3. Undersigned counsel received the record on appeal promptly thereafter.
However, the record on appeal consists of twelve (12) volumes of trial
transcripts and additional time will be necessary to review said record,
conduct the required research, and prepare the Initial Brief.
4. Accordingly, in the abundance of caution, Defendant-Appellant
Christopher Ernest Braughton respectfully requests that this Court grant a 45-
day extension of time, up to and including September 25, 2015, to file the
Initial Brief in this cause.
5. This extension of time is not requested for the purpose of delay, but so
that the issues on appeal are presented in the clearest and most effective
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manner so that justice may be done in this cause. This is Defendant-
Appellant’s first request for an extension of time.
WHEREFORE, Premises Considered, Defendant-Appellant respectfully
requests the entry of an order granting a 45-day extension of time, up to and
including September 24, 2015, to file the Initial Brief and to provide such further
and other relief that the Court may deem just, fair and equitable.
Respectfully Submitted,
/s/ Robert L. Sirianni, Jr.
Robert L. Sirianni, Jr.
THE LAW OFFICE OF ROBERT L. SIRIANNI, JR.
Texas Bar No. 24086378
BROWNSTONE, P.A.
201 N. New York Ave. Suite 200
P.O. Box 2047
Winter Park, Florida 32790
Tele: 407.388.1900
Fax: 407.622.1511
Robert@brownstonelaw.com
Counsel for Defendant-Appellant
CERTIFICATE OF CONFERENCE
On July 27, 2015, the office of undersigned counsel conferred with the assistant to
Alan Curry. Alan Curry does not oppose this motion.
/s/ Robert L. Sirianni, Jr.
Robert L. Sirianni, Jr., Esq.
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CERTIFICATE OF SERVICE
Undersigned hereby certifies that on this 1st day of August, 2015, the
foregoing document has been served by U.S. Mail, first-class postage prepaid, upon
the following:
Alan Curry
Chief Prosecutor, Appellate Division
Harris County District Attorney’s Office
1201 Franklin, Ste. 600
Houston, TX 77002
/s/ Robert L. Sirianni, Jr.
Robert L. Sirianni, Jr., Esq.
CERTIFICATE OF COMPLIANCE
Undersigned counsel certifies that the body of this document contains 256
words according to Microsoft Word.
/s/ Robert L. Sirianni, Jr.
Robert L. Sirianni, Jr., Esq.
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