Daniel Vadnais v. State

Opinion

ACCEPTED

03-14-00578-CR

3788792

THIRD COURT OF APPEALS

AUSTIN, TEXAS

1/15/2015 4:34:53 PM

JEFFREY D. KYLE

CLERK

IN THE THIRD COURT OF APPEALS FOR THE STATE OF TEXAS

FILED IN

DANIEL VADNAIS 3rd COURT OF APPEALS AUSTIN, TEXAS

V. NO. 03-14-00578-CR 1/15/2015 4:34:53 PM

JEFFREY D. KYLE

THE STATE OF TEXAS Clerk

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

TO THE HONORABLE THIRD COURT OF APPEALS:

COMES NOW, Daniel Vadnais, by and through his attorney of record, Dal Ruggles, and files this, his First Motion for Extension of Time to File Brief, and in support thereof would show the Court the following:

I.

That the above styled and numbered cause is styled The State of Texas v. Daniel Vadnais, Cause Number CR-13-0651 in the 22nd Judicial District Court of Hays County, Texas. Appellant was sentenced on August 13, 2014.

II.

Appellant was convicted on one count of Fraudulent Use or Possession of Identifying Information. Punishment was assessed at ten (10) years imprisonment.

III.

Appellant’s notice of appeal was filed on August 28, 2014 and a motion for new trial was filed on September 11, 2014. The clerk’s record and reporter’s record were filed on December 11, 2014. The due date for the brief is Thursday, January 15, 2015.

IV.

This is Appellant’s first motion for extension of time to file his brief. Appellant

2

respectfully requests a forty-five day extension of time to file the brief, which would make such brief due on Monday, March 2, 2015.

V.

The undersigned attorney has been unable to complete the brief due to lack of time. The Reporter’s record was filed last month and counsel’s workload has been such that he has not been able to devote sufficient time to complete the brief. He asks that this extension be granted so that he may effectively represent Appellant and so that justice may be done in this case.

Respectfully Submitted,

_/s/_Dal Ruggles_________________ DAL RUGGLES

Attorney at Law

1103 Nueces St.

Austin, Texas 78701

Phone: (512) 477-7991

Facsimile: (512) 477-3580 SBN: 24041834

Email: dal@ruggleslaw.com

ATTORNEY FOR APPELLANT

CERTIFICATE OF SERVICE

I, Dal Ruggles, hereby certify that a true and correct copy of the foregoing Appellant’s First Motion for Extension of Time to Brief was e-served to Ms. Kathleen Magee Arnold of the Hays County District Attorney's Office on this the 15th day of January, 2015.

_/s/_Dal Ruggles____________ DAL RUGGLES