FILED IN
AP-77,045
COURT OF CRIMINAL APPEALS
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
October 28, 2015 Transmitted 10/28/2015 2:04:24 PM
Accepted 10/28/2015 2:28:36 PM
ABELACOSTA, CLERK ABEL ACOSTA
No. AP-77,045
CLERK
HARLEM HAROLD LEWIS, HI § IN THE COURT
§
§ OF CRIMINAL APPEALS
§
THE STATE OF TEXAS § AUSTIN, TEXAS
FINAL 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: November 6, 2015
6. Length of Extension Requested: 60 days
7. Number of Previous Extensions: Two 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, which has been ongoing. 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. Counsel has made
considerable progress and does not anticipate requesting any further extensions
in this complex case.
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
. (281)379-6901
FAX: (832) 813-0321
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