ACCEPTED 06-14-00236-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 4/29/2015 9:45:57 AM DEBBIE AUTREY CLERK No. 06-14-00236-CR FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS PAUL ANTWANN HARLAN § IN THE 6TH4/29/2015 DISTRICT9:45:57 AM DEBBIE AUTREY V. § COURT OF APPEALS Clerk

THE STATE OF TEXAS § AT TEXARKANA, TEXAS

MOTION FOR AN EXTENSION OF TIME TO FILE APPELLANT’S BRIEF

TO THE HONORABLE JUDGES OF SAID COURT: COMES NOW Paul Antwann Harlan, Appellant in this cause, by and through his duly appointed attorney on appeal, and requests that this Court extend the time for filing Appellant’s Brief from April 29, 2015, to May 29, 2015. In support of this motion, Appellant would show the Court the following: I.

A grand jury indicted Appellant for aggravated robbery. (CR: 10). Appellant pleaded not guilty to the charge. (RR3: 8; RR4: 13). A jury found Appellant guilty and assessed a punishment of 50 years’ imprisonment and a $10,000 fine. (CR: 96; RR5: 88; RR6: 14-15). The trial court overruled Appellant’s motion for new trial. (CR: 86). Appellant timely filed his notice of appeal. (CR: 88).

II.

The due date for Appellant’s Brief is April 29, 2015. The case is not yet set for submission.

III.

Appellant requests an extension of time of thirty (30) days in which to file Appellant’s Brief. No previous extension of time has been requested by Appellant or granted to Appellant.

IV.

Appellant submits that a reasonable explanation exists for this requested extension. Appellant relies on the following facts to reasonably explain why the brief has not yet been prepared and the need for an extension of time in which to file Appellant’s Brief: (1) The undersigned attorney has started reviewing the record in this case.

However, she is in the process of determining whether the trial court clerk has a copy of the jury charge and verdict form for the punishment phase of Appellant’s jury trial. To date, this issue has not been resolved, and the undersigned attorney needs additional time to review this particular matter for potential legal error.

(2) Since March 30, 2015, the date the reporter’s record was filed in this cause, the undersigned attorney has filed briefs in the following cases:

a. David Newton v. State of Texas, Appellate Cause No. 05-14- 01452-CR, Motion to Withdraw and Brief in Support of Motion to Withdraw filed on March 31, 2015.

b. Christopher Njoku v. State of Texas, Appellate Cause No. 05-14- 01201-CR, Appellant’s Brief filed on April 29, 2015.

In short, the undersigned attorney simply has not yet had an opportunity to read, evaluate and brief the case at bar.

V. This Motion is not brought for purposes of delay but so that the appellate record can be read and evaluated, and so that the legal and factual issues presented by the appellate record can be properly briefed and presented to this Court on Appellant’s behalf.

WHEREFORE, Appellant requests this Court extend Appellant’s deadline to file his brief to May 29, 2015.

Respectfully submitted,

/s/ Julie Woods Lynn Richardson Julie Woods Chief Public Defender Assistant Public Defender Dallas County, Texas State Bar No. 24046173 Frank Crowley Courts Building N. Riverfront Blvd., LB-2 Dallas, Texas 75207-4399 (214) 653-3550 (phone) (214) 653-3539 (fax) [email protected]

CERTIFICATE OF SERVICE I hereby certify that a true copy of the foregoing motion was served on the Dallas County Criminal District Attorney’s Office (Appellate Division), 133 N.

Riverfront Blvd., LB-19, 10th Floor, Dallas, Texas 75207, by eServe on April 29, 2015.

/s/ Julie Woods Julie Woods