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 would 

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

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 8/24/2015 9:38:28 AM CHRISTOPHER A. PRINE Clerk
IV.

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

research and preparation of Appellant'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, 56th District Court;

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

14CR1791, 56th District Court;

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

14CR2877 & 15CR1476, 56th 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 CONSIDERED, 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 59th 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 provided 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 59th Street, Galveston, Tx. 77551, 

on the 24th 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 is 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