Chelsea Podowski v. State

Opinion

ACCEPTED

03-15-00109-CR

7809662

THIRD COURT OF APPEALS

AUSTIN, TEXAS

11/12/2015 5:21:05 PM

JEFFREY D. KYLE

CLERK

NO. 03-15-00109

CHELSEA PODOWSKI § IN THE THIRD FILED COURT IN

3rd COURT OF APPEALS

AUSTIN, TEXAS

V. § OF APPEALS 11/12/2015 5:21:05 PM

JEFFREY D. KYLE

THE STATE OF TEXAS § IN AUSTIN, TEXAS Clerk

APPELLANT’S THIRD MOTION TO EXTEND TIME TO FILE REPLY TO APEELLEE’S BRIEF

COMES NOW Chelsea Podowski, Appellant in the above-styled and numbered

cause, by and through his undersigned counsel, and respectfully moves this Court

to extend the time to file Appellant’s brief. In support thereof, and pursuant to

TEX. R. APP. PROC. 10.5(b), Appellant would show as follows:

(A) Appellant’s Reply to Appellee’s Brief is due on November 9, 2015;

(B) Appellant seeks a 3 day extension until November 12, 2015;

(C) Undersigned counsel delivered the Reply brief on time to opposing

counsel. However, when attempting to e-file, the electronic envelope was

not finalized until the next morning, on November 10th. The Court’s Clerk

also requested counsel to amend the delivered reply by including a

certificate of compliance by November 12, 2015. No other changes have

been made to the brief submitted on November 10, 2015 other than the requested certificate of compliance has been included in the amended brief

filed on November 12, 2015.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that the foregoing

motion be GRANTED.

Respectfully submitted,

________/s/ James Gill_______ JAMES GILL 1201 Rio Grande Street, Ste. 200 Austin, Texas 78701 (512) 448-4560 (512) 308-6780 (Fax) jgill@austin-criminallawyer.com State Bar No. 24043692 ATTORNEY FOR APPELLANT

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing Appellant’s Third

Motion to Extend Time to File Reply Brief was served on the Travis County

District Attorney, P.O. Box 1748, Austin, Texas, 78767, by electronic transmission

(TCAppellate@traviscountytx.gov) and the Court of Appeals, on this the 12th day

of November 2015.

________/s/ James Gill_______

JAMES GILL