FILED IN COURT OF CRIMINALAPPEALS March 19,2015 ABELACOSTA, CLERK NO. AP-77,045 AP-77,045 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 3/19/2015 9:07:27 AM

Accepted 3/19/2015 10:09:20 AM ABEL ACOSTA CLERK IN THE COURT OF CRIMINAL APPEALS FOR THE STATE OF TEXAS

* * *
HARLEMHAROLD LEWIS III, Appellant

v. THE STATE OF TEXAS, Appellee

* * * APPELLANT'S SECOND AND FINAL MOTION FOR EXTENSION OF TIME WITHIN WHICH TO FILE APPELLANT'S BRIEF
*Death Penalty Case*
OnAppeal in Cause No. 1428102 from the 

### 351st District Court of HarrisCounty, Texas

TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS: HARLEM HAROLD LEWIS III, Appellant in the above cause, 

### respectfully requests thatthe Court grant this Motion for Extension ofTime

### Within Which to File Appellant's Brief. In support of this motion, Appellantrespectfully shows the Courtthe following:

This Appeal is based upon Appellant's conviction ofCapital Murder and sentence ofdeath in Harris County in State ofTexas v. Harlem Harold Lewis III in Cause No. 1428102. This is Appellant's second request for an extension oftime.
II. Appellant's brief is currently due on March 23, 2015. Counsel 

### respectfully requests an extension oftime until Monday, June 8, 2015.
III. 

### The Reporter's Record was filed with this Court on November 21, 

### 2014. Appellant initially requested an extension oftime to submit the brief until Monday, June 15, 2015. This Court granted an extension of time requiring thatthe briefbe submittedbefore March 23, 2015.
IV. 

### Appellantrequests thatthe Court allow the briefto be filed by June 8, 2015, less than 80 days afterthe currentdue date.V. 

### Counsel has been preparing for a retrospective competency trial in a death penalty case remanded by this Court in Cause No. AP-76,580 Albert James Turner v. State ofTexas. As part ofthat proceeding, Counsel filed a Petition for Writ ofMandamus and Prohibition with this Court, In re Albert James Turner Cause No. WR-80,559-02. Most recently, the State filed a Petition for Writ ofMandamus and Prohibition with this Court, In re Albert James Turner Cause No. WR-82,875-01, prompting this Court to order 

### Counsel to submitbriefing no laterthan April 3, 2015.
VI. Additionally, Counsel is working on U.S. v. James Ham, Cause No. 4:2013cr-00363, a federal Death Penalty case in the Southern District of 

### Texas set for trial this fall. Counsel also has supplemental briefing due to 

### the4th Court ofAppeals inKimberly Saenz v. State ofTexas Cause No. 04- 12-00238-CR by April 8, 2015, a non-death capital that this Court remanded.
VII. 

### Counsel has reviewed the Clerk's and Reporter's Records, examined 

### the presently available audio visual exhibits and requested the remaining

### ones, identified more than a dozen potential errors, and is continuing to research each issue to identify the strongest points to present to the Court. This motion is not made for the purpose ofdelay, but only so that Appellant may receive the effective assistance of counsel to which he is entitled by
means ofa thorough and professional presentation ofhis points oferror to this Court. 

### WHEREFORE, PREMISES CONSIDERED, Appellantprays thatthis Honorable Court will grant this requested extension of time to file the Appellant's Briefin the above cause and extendthe time for filing until June 8,2015. Respectfully submitted, Isi Robert A. Morrow ROBERT A. MORROW State Bar No. 14542600 24 Waterway Ave., Suite 660 The Woodlands, Texas 77380 

### Telephone: (281) 379-6901 ramorrow15@gmail.com

Isi Amy Martin AMY MARTIN State Bar No. 24041402 202 Travis Street, Suite 300 Houston, Texas 77002 

### Telephone: (281) 809-0873 

### amymartinlaw@gmail.com A TTORNEYSFOR APPELLANT APPOINTED ONAPPEAL ONLYCERTIFICATE OF SERVICE As required, and in accordance with, the Texas Rule of Appellate 

### Procedure, I certify thatIhave servedthis document on the following parties on March 19, 2015:
Harris County DistrictAttorney's Office Appellate Division 1201 Franklin, Suite 600 Houston, Texas 77002 Ph. 713-755-5826 Fax:713-755-5809

Isi Robert A. Morrow ROBERT A. MORROW