Daniel Vadnais v. State

Opinion

ACCEPTED

03-14-00578-CR

5492498

THIRD COURT OF APPEALS

AUSTIN, TEXAS

6/1/2015 2:28:35 PM

JEFFREY D. KYLE

CLERK

NO. 03-14-00578-CR

COURT OF APPEALS FILED IN 3rd COURT OF APPEALS

AUSTIN, TEXAS

FOR THE

6/1/2015 2:28:35 PM

JEFFREY D. KYLE

AUSTIN SUPREME JUDICIAL DISTRICT Clerk

DANIEL RAYMOND VADNAIS, Appellant

VS.

THE STATE OF TEXAS, Appellee

APPEAL FROM

THE 22ND JUDICIAL DISTRICT COURT

HAYS COUNTY, TEXAS

TRIAL COURT CAUSE NO. CR-13-0651

First Motion For Extension of Time in Which to File State's Brief

Whitney Borgman Asst. Criminal District Attorney 712 S. Stagecoach Trail, Suite 2057 San Marcos, Texas 78666 Ph: (512) 878-6544/Fax: (512) 393-2246 State Bar No. 24082224 whitney.borgman@co.hays.tx.us Attorney for the State of Texas

TO THE HONORABLE JUSTICES OF THE THIRD COURT OF APPEALS:

The State files this First Motion for Extension of Time in Which to File

State's Brief, and in support states:

1. The State's current deadline for filing its brief is June 1, 2015.

2. This is the State's first Motion for Extension of Time in which to file

its brief.

3. The State respectfiilly requests an extension of approximately sixty days, until July 31, 2015 in which to file its brief.

4. Good cause exists for the State's request for extension of time in which to file its brief. The attorney of record delivered her child 7 weeks

prematurely. This office requests additional time for reassignment of State's Brief.

5. These circumstances have significantly delayed the completion of this brief.

6. This extension is not being sought to cause undue delay, but to seek justice.

7. For the foregoing reasons, the State respectfiilly requests that the Court grant an approximate sixty day extension for filing Appellee's Brief, until July 31, 2015.

Respectfully submitted,

Whitney Bo^gjfian Asst. Criminal District Attorney Hays County Government Center 712 South Stagecoach Trail, Ste. 2057 San Marcos, Texas, 78666 512-878-6544 whitney.borgman@co.hays.tx.us State Bar No. 24082224 Attorney for the State of Texas

The foregoing Appellant Motion for Extension of Time in Which to File Appellant's Brief was subscribed and sworn to before me by Whitney Borgman on this the 1st of June, 2015.

\^itney Borgmap (_

RHONDA WIEDERSTEIN ]*) MY COMMISSION EXPIRES September 9,2018

Notary Public in and for the State of Texas

CERTIFICATE OF SERVICE

I certify that on June 1, 2015, I served the above motion by email to Dal Ruggles at dal@ruggleslaw.com, in accordance with the Texas Rules of Appellate Procedure.

Whitney Borgi^n /