PD-1258-15 PD-1258-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 9/23/2015 4:45:14 PM Accepted 9/24/2015 4:09:46 PM ABEL ACOSTA CAUSE NO. 14-14-00142-CR CLERK THE STATE OF TEXAS § TEXAS COURT § VS. § OF § ROGELIO AVILES-BARROSO § CRIMINAL APPEALS

MOTION FOR EXTENSION OF TIME TO THE HONORABLE JUDGES OF THIS COURT: COMES NOW Gerald E. Bourque, appointed capital appellate counsel for Appellant Rogelio Aviles-Barroso in the above styled-and-numbered causes of action.

Pursuant to Texas Rule of Appellate Procedure Rule 38.6(d), Appellant requests additional time to file his petition for discretionary review (PDR) for the following reasons: I.

On August 27th, 2015, the Fourteenth Court of Appeals affirmed Mr. Barroso’s capital murder conviction. Appellant’s current deadline to file his PDR is September 28, 2015. Counsel has two capital murder trials set on 10/5/15 and 10/12/15. To effectively represent these capital defendants and research and draft Appellant’s PDR, appellate counsel needs additional time. Appellate counsel asks this court for an extended deadline of November 12th, 2015. This is counsel’s first request for an extension of time.

WHEREFORE, PREMISES CONSIDERED, Defendant respectfully prays that this Honorable Court will grant this, Appellant’s Motion for Extension of Time.

Respectfully submitted,

/s/ Gerald E. Bourque GERALD E. BOURQUE September 24, 2015 24 Waterway Ave., Suite 660 The Woodlands, TX 77380 Telephone: 713-862-7766 Facsimile: 832-813-0321 [email protected] Texas State Bar #02716500

CERTIFICATE OF SERVICE: On September 23, 2015, I emailed Appellant’s Motion for Extension of Time to the Appellate Division of the Harris County District Attorney’s Office via efile.txcourts.gov.

/s/ Gerald E. Bourque Gerald E. Bourque Attorney for Mr. Barroso