No: 01−15−00393−CR

In the

Court of Appeals

FIRST DISTRICT OF TEXAS

Houston, Texas

__________________________________________________________________

CHRISTOPHER ERNEST BRAUGHTON

Appellant,

v.

THE STATE OF TEXAS

Appellee. 

__________________________________________________________________

Appealed from the 228th Judicial District Court of

Harris County, Texas, the Honorable Marc Carter, Presiding

__________________________________________________________________

MOTION TO EXTEND TIME TO FILE BRIEF BY TEN DAYS

__________________________________________________________________

Niles Illich

SBOT: 24069969

Law Office of Niles Illich, Ph.D., J.D.

701 Commerce Street 

Suite 400

Dallas, Texas 75202

Telephone: (972) 802 − 1788

Facsimile: (972) 682 – 7586

Email: Niles@appealstx.com

ATTORNEY FOR APPELLANT

CHRISTOPHER ERNEST BRAUGHTON 

ACCEPTED

01-15-00393-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS

9/21/2015 3:30:36 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 9/21/2015 3:30:36 PM CHRISTOPHER A. PRINE Clerk
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To the Honorable Justices of the First Court of Appeals:

Appellant, Christopher Ernest Braughton files this, his Motion to Extend Time 

to File Brief by Ten Days.

Christopher Braughton asks this Court to grant his attorney ten additional days 

to file Appellant’s brief, making it due on Sunday, October 4, 2015.

Motion to Extend Time to File Brief

Braughton requests that his attorney receive an additional ten days in which 

to file his brief, making it due on Sunday, October 4, 2015.

Introduction

1. Appellant is Christopher Braughton and the Appellee is the State of Texas.

This appeal concerns an appeal of a conviction for murder.

2. Appellant was tried in 228th Judicial District Court of Harris County, Texas.

Argument and Authorities

3. There is no specified deadline to file a motion to extend time to file an 

appellant’s brief.1

4. Appellant’s brief is due on Thursday, September 24, 2015.

5. Braughton, under his previous attorney, received one previous extension of 

time.

 1 TEX. R. APP. P. 38.6(d).
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6. Counsel asks for this extension of time because he is completing a brief in 

cause number 09−15−00159−CR which is due on September 23, 2015. This brief 

concerns a combat veteran who was injured in Afghanistan but who has been 

convicted of several criminal offenses since being discharged from the Army. This 

brief included a lengthy motion for new trial and argues that the trial counsel was 

constitutionally ineffective. Additionally, counsel filed two briefs on September 15, 

2015 (cause numbers 05-15-00886-CV and 05-14-01606-CR) and on that same day 

participated in an oral argument as the Appellee/Cross-Appellant in a seven-issue 

brief in cause number 05-14-00810-CV.

7. Braughton’s brief is nearly complete and contains three issues. Counsel asks 

for ten additional days so that the issues may be refined and so that the cases and 

record citations can be verified. No additional requests for time will be made.

Prayer and Conclusion

8. Braughton requests that this Court grant his counsel an additional ten days in 

which to file his brief. This extension will make the brief due on Sunday, October 

4, 2015. There is no reason to believe that further extensions will be requested. 
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Respectfully Submitted,

/s/ Niles Illich 

Niles Illich

The Law Office of Niles Illich, Ph.D., J.D.

701 Commerce Street

Suite 400

Dallas, Texas 75202-4518

Direct: (972) 802-1788

Fax: (972) 236-0088

Email: Niles@appealstx.com

CERTIFICATE OF CONFERENCE

On September 21, 2015 Niles Illich spoke with Eric Kugler of the Appellate 

Division of the Harris County District Attorney’s Office concerning this Motion. 

Mr. Kugler stated that he is unopposed to this Motion.

/s/ Niles Illich 

Niles Illich
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CERTIFICATE OF SERVICE

This is to certify that, on September 21, 2015, a true and correct copy of this

Motion to Substitute Counsel has been served on:

VIA ELECTRONIC SERVICE

Harris County District Attorney’s Office

Alan Curry

1201 Franklin Street

Suite 600

Houston, Texas 77002-1923

Electronic Mail: Alan.Curry@dao.hctx.net

VIA FIRST CLASS POST

Christopher Ernest Braughton

Texas Department of Criminal Justice

Holliday Unit

295 I.H. 45 North

Huntsville, TX 77320-8443

TDCJ No.: 01982320

/s/ Niles Illich 

Niles Illich