IN THE COURT OF APPEALS

FOR THE FIRST SUPREME JUDICIAL DISTRICT

AT HOUSTON, TEXAS

JAMES JESSE HUBBARD, §

Appellant §

vs. § CASE NO. 01

- 15

- 00342

- CR

§ TRIAL COURT NO: 14CR0848

THE STATE OF TEXAS, §

Appellee §

APPELLANT’S FIRST MOTION FOR EXTENSION OF

TIME TO FILE APPELLANT’S BRIEF

TO THE HONORABLE COURT OF APPEALS:

NOW COMES, JAMES JESSE HUBBARD, the Appellant herein, and moves the Court for

an extension of time to file Appellant's Brief in this cause, pursuant to Rule 38.6(d) of the Texas

Rules of Appellate Procedure, and in support thereof would show the Court as follows:

I.

The Appellant in this cause was convicted in the 405th District Court of Galveston County,

Texas in cause number 14CR0848 with the felony offense of Robbery and his punishment was

assessed at 40 years TDC.

II.

Appellant’s brief is due on or before August 24, 2015.

III.

The Appellant hereby requests an extension of time to file Appellant's Brief, and wou ld

show unto the Court that 45 additional days should be sufficient to allow the completion of

Appellant's Brief. ACCEPTED

01-15-00342-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS

8/24/2015 9:38:28 AM

CHRISTOPHER PRINE

CLERKIV.

The undersigned counsel has been unable to devote sufficient time to the review of the record,

research and preparation of Appellan t's Brief for the following good and sufficient reasons:

Appellant’s counsel was/is set for jury trials during the two week trial period beginning

August 24, 2015, on the following cases:

State of Texas vs. Derek Wells, Murder, # 14CR1983, 56 th District Court;

State of Texas vs. Kevin Wilson, Manslaughter and Aggravated Assault, # 14CR1790 &

14CR1791, 56 th District Court;

State of Texas vs. Joseph Bourgeois, Intoxication Manslaughter and Aggravated Assault, #

14CR2877 & 15CR1476, 56 th District Court;

Appellant’s counsel has been preparing for these trials for the most part of August 2014.

V.

Due to the above

- referenced, Appellant’s counsel respectfully requests a 45 day extension to

file Appellant’s brief in this cause.

WHEREFORE, PREMISES CONSIDER ED, the undersigned counsel, on behalf of

Appellant, respectfully prays that this Honorable Court extend the time for filing Appellant's Brief

in this cause.

RESPECTFULLY SUBMITTED,

/s/ Greg Russell

Greg Russell

Attorney for Appellant

711 59 th Street

Galveston, Texas 77551

(409) 497

- 4743

(409) 497

- 4721 Fax

SBN: 17411550

### CERTIFICATE OF SERVICE

As Attorney of Record for Appellant, I do hereby Certify that a true and correct

copy of the above and foregoing document was this date provid ed to the Attorney for

Appellee, Mr. Jack Roady, District Attorney of Galveston County at the offices of the

District Attorney of Galveston County, Texas, 600 59 th 

### Street, Galveston, Tx. 77551,

on the 24 th 

### day of August 2015, via certified electronic service provider.

/s/ Greg Russell

Attorney for Appellant

CERTIFICATE OF COMPLIANCE

I do hereby certify that this brief i s in compliance with rule 9.4(i) of the

Texas Rules of Appellate Procedure because it is computer generated, and its

relevant portions contain 479 words.

/s/ Greg Russell

Attorney for Appellant