Christopher Jaroszewicz v. Texas Department of Public Safety

• Court: Court of Appeals of Texas
• Decided: August 18, 2015
• Docket: 03-15-00340-CV
• Status: Published

Opinion

ACCEPTED 03-15-00340-CV 6539616 THIRD COURT OF APPEALS AUSTIN, TEXAS 8/18/2015 11:30:47 AM 03 CV JEFFREY D. KYLE CLERK CAUSE NO. 01-15-00340-CR

IN THE COURT OF APPEALS FILED IN 3rd COURT OF APPEALS FOR THE AUSTIN, TEXAS THIRD JUDICIAL DISTRICT OF TEXAS8/18/2015 11:30:47 AM AUSTIN, TEXAS JEFFREY D. KYLE Clerk ______________________________________________________________________

CHRISTOPHER JAROSZEWICZ, APPELLANT

VS.

TEXAS DEPARTMENT OF PUBLIC SAFETY, APPELLEE ______________________________________________________________________

ON APPEAL FROM THE COUNTY COURT AT LAW NO. TWO TRAVIS COUNTY, TEXAS TRIAL COURT NO. C-1-CV-15-001468 ______________________________________________________________________

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

KEVIN FINE State Bar No. 00790682 P.O. Box 312 Boerne, Texas 78006 512-593-1383/Hill Country (ofc) 713-299-1923/Houston (cell) 888-803-8721 kfine@kevinfinelaw.com

ATTORNEY FOR APPELLANT TO THE HONORABLE JUSTICES OF THE THIRD COURT OF APPEALS:

COMES NOW, Christopher Jaroszcewicz, Appellant in the above-styled and

numbered cause and, pursuant to TEX. R. APP. P. 10.5(b) and 38.6(d), files this

Motion to Extend Time to File Appellant's Brief, and with respect thereto, would

show the Court the following:

Appellant's Brief is currently due on August 17, 2015.

Counsel for Appellant requests a 30 day extension of time to file Appellant’s

Brief making the brief due on September 16, 2015. This is Appellant’s first

request for extension of time to file the opening brief.

Counsel for Appellant relies on the following reasons, in addition to the

routine matters that counsel must attend to in daily practice, to explain the need for

the requested extension.

Counsel was not provided a copy of the Clerk’s Record and was only

recently provided a copy of the Reporter’s record in this case. Counsel for

Appellant seeks this extension of time to be able to properly and thoroughly

prepare Appellant’s Brief. This request is not sought for delay, but so that justice

may be done.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Appellant prays the Court

grant this motion.

1 RESPECTFULLY SUBMITTED,

__/s/ Kevin Fine_______________ KEVIN FINE State Bar No. 00790682 P.O. Box 312 Boerne, Texas 78006 512-593-1383/Hill Country (ofc) 713-299-1923/Houston (cell) 888-803-8721 kfine@kevinfinelaw.com

ATTORNEY FOR APPELLANT

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above motion was provided to the Travis County Attorney’s Office via efiling on this the 18th day of August, 2015. ___/s/ Kevin Fine_____________ KEVIN FINE

CERTIFICATE OF CONFERENCE

I hereby certify that I conferred with counsel for Appellee, Mr. Kevin Givens, and he has no opposition to Appellant’s motion. SIGNED this the 18th day of August, 2015.

___/s/ Kevin Fine______________ KEVIN FINE