Texas Department of Public Safety v. Louis Leroy Kuhn

Opinion

ACCEPTED

06-15-00083-CV

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS 12/8/2015 3:49:50 PM

DEBBIE AUTREY

CLERK

NO. 06-15-00083-CV

FILED IN

IN THE COURT OF APPEALS 6th COURT OF APPEALS TEXARKANA, TEXAS 12/8/2015 3:49:50 PM

FOR THE DEBBIE AUTREY Clerk

SIXTH SUPREME JUDICIAL DISTRICT OF TEXAS

AT TEXARKANA

TEXAS DEPARTMENT OF PUBLIC SAFETY § Appellant

V. §

LOUIS LEROY KUHN § Appellee

APPELLEE'S REQUEST FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE COURT OF APPEALS:

Counsel for Appellee requests an Extension of Time to File the Appellee's Brief; the following is satisfied:

1. The trial court number is 15-0348C;

2. The County Court at Law of Hays County rendered judgment on August

11, 2015;

3. Notice of Appeal was filed by Appellant (Texas Department of Public

Safety) on September 10, 2015;

4. Appellant’s Brief was filed on November 9, 2015;

5. Appellee has only recently been capable of securing Appellee Counsel

and was retained by Appellee by and through the Trial Counsel on

December 1, 2015;

6. Counsel has since begun researching this matter, reviewing Appellant's

Brief, the record and the law. Counsel has not received a copy of the

Reporter’s Record, however is in the process of securing such.

Appellee prays that this Court grant an extension of sixty (60) days in order

to allow for the formal filing of Appellee’s Brief to consider this matter on it’s

merits.

Respectfully submitted,

! Scot Courtney Attorney for Appellee P. O. Box 787 San Marcos, Texas 78667-0787 512-392-9292 512-532-6766 FAX State Bar #00790515

CERTIFICATE OF SERVICE

By affixing his signature to the foregoing instrument, Scot Courtney certifies that a true and correct copy of the same has been delivered via email to the offices of the below-listed counsel, on this the 8th day of December, 2015.

! Scot Courtney

Kevin M. Givens Texas Department of Public Safety Kevin.Givens@dps.texas.gov

CERTIFICATE OF CONFERENCE By affixing his signature to the foregoing instrument, Scot Courtney certifies that Counsel has conferred with Appellate Counsel and Appellate Counsel, listed below does not oppose the Motion.

! Scot Courtney

Kevin M. Givens Texas Department of Public Safety Kevin.Givens@dps.texas.gov

VERIFICATION

STATE OF TEXAS §

COUNTY OF HAYS §

BEFORE ME, the undersigned authority on this day, personally appeared Scot Courtney, who did depose and state as follows:

"My name is Scot Courtney. I have read the foregoing Motion. All facts contained therein are true and correct."

! Scot R. Courtney

SWORN AND SUBSCRIBED to before me, the undersigned authority

on this the ______ day of ____________________, 2015.

________________________________

NOTARY PUBLIC IN AND FOR THE STATE OF TEXAS