Page 3 IN THE TWELFTH COURT OF APPEALS

CAUSE NO. 12-14-00287-CR
BRANDEE MICHELLE NICHOLS § ON APPEAL FROM THE Appellant VS. § 114 TH DISTRICT COURT THE STATE OF TEXAS, Appellee § SMITH COUNTY, TEXAS

THIRD MOTION FOR EXTENSION OF TIME TO FILE THE APPELLANT’S BRIEF
TO THE HONORABLE COURT OF APPEALS AND THE JUSTICES THEREOF:

COMES NOW APPELLANT, BRANDEE MICHELLE NICHOL, the Appellant, and moves the Court for an Third Extension of Time to File the Appellant’s Brief in this cause and in support thereof would show the Court as follows: I. The Reporter’s Record was filed on December 3, 2014. According to the correspondence the Appellant’s Brief is due to be filed on Monday, April 6, 2015. II. Appellant, respectfully request that pursuant to T.R.A.P. 10.5(d) 38.6 (d) that the Court grant an Extension of Time to file Appellant’s Brief until the 7 thday of April, 2015, and in support thereof would respectfully show the Court that during the previous thirty (30) days Counsel has been involved in the following: ACCEPTED 12-14-00287-cr TWELFTH COURT OF APPEALS

TYLER, TEXAS 4/6/2015 4:35:28 PM CATHY LUSK CLERKPage 3 1. Appellant’s Counsel has also been involved i n capital murder pre-trials in the case

styled the State of Texas v. Calvert . This case has been especially time intensive due to the nature of the case, ie a pro se Defendant in a deat h penalty case inn Smith County, Texas . The Trial Court has ordered standby counsel to prepare a collateral defense in the event the defendant decides he wants representation. This case is set t o commence jury selection on April 23, 2015. Counsel has also been meeting with the Defendant an d the DA in Wood County in conjunction with the State v. McDaniel a capital murder prosecution. On Wednesday, April 1, 2015, there was a mulit- defendant federal drug bust and Counse l spent most of Wednesday in Federal Court and meeting with his client in the Gregg County Jai l on Thursday. Counsel has been researching issues and preparing his brief, the brief is 90% co mplete and Trial Counsel request an additional day to finish the brief, shepardize cases etc. 2. Undersigned Counsel has been involved with othe r numerous federal cases and state misdemeanor and felony cases in the preceding 30 da y period. 3. Undersigned Counsel respectfully requests this Honorable Court to extend the time for filing the Appellant’s Brief until the 7th day of A pril, 2015, in order to afford the undersigned Counsel the necessary time to finish the Appellant’ s Brief. WHEREFORE PREMISES CONSIDERED, the undersigned Coun sel, respectfully prays that his Honorable Court extend the time for filing Appellant’s Brief in this cause until the 7 th day of April, 2015. Respectfully submitted, JEFF L. HAAS Attorney at Law 908 First City P lace Tyler, Texas 75 702Page 3

(903) 593-8338 /s/ Jeff Ha as JEFF L. HAAS STATE BAR NO. 08659600 ATTORNEY FOR APPELLANT

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of th e above and foregoing Motion for Extension of Time to File Appellant’s Brief has be en delivered to the District Attorney's Office of Smith County, Texas, on this the 6 th day of April, 2015

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/s/ Jeff Haas JEFF L. HAASPage 3