ACCEPTED
03-14-00495-CR
3785343
THIRD COURT OF APPEALS
AUSTIN, TEXAS
1/15/2015 2:56:45 PM
JEFFREY D. KYLE
CLERK
NO. 03-14-00495-CR
IN THE FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
COURT OF APPEALS 1/15/2015 2:56:45 PM
JEFFREY D. KYLE
THIRD JUDICIAL DISTRICT Clerk
AT AUSTIN, TEXAS
__________________________________________________________________
ISAAC BENAVIDEZ. APPELLANT
V.
THE STATE OF TEXAS, APPELLEE
__________________________________________________________________
MOTION TO FILE STATE’S BRIEF LATE
__________________________________________________________________
Appeal from the 21st Judicial District Court
Bastrop County, Texas
Honorable Christopher D. Duggan
Cause Number 15266 Counts One and Three
__________________________________________________________________
Bryan Goertz
Criminal District Attorney
Philip L Hall, Assistant
Criminal District Attorney
Bastrop County, Texas
804 Pecan Street
Bastrop , Texas 78602
State Bar Number 00787626
Phone (512) 581-4016
Fax (512) 581-7133
NO. 03-14-00495-CR
IN THE COURT OF APPEALS
THIRD JUDICIAL DISTRICT
AT AUSTIN, TEXAS
__________________________________________________________________
ISAAC BENAVIDEZ, APPELLANT
V.
THE STATE OF TEXAS, APPELLEE
__________________________________________________________________
TO THE HONORABLE COURT OF APPEALS:
The State of Texas respectfully requests the court to accept the State’s Brief
in this cause and would show the following:
I.
The State’s Brief in this cause was due on December 29, 2014.
II.
The State’s Brief in this cause was submitted to the court on January 15,
2015.
III.
The State’s attorney failed to accurately notate the due date on the calendar.
IV.
The State’s attorney was not in the office from January 5, 2015 through
January 9, 2015 because he was a faculty advisor at the Texas District and County
Attorneys Association Prosecutor Trial Skills Course in Austin, Texas.
V.
Due to a family emergency of a colleague, the State’s attorney tried the State
of Texas v. Beau Awtrey, Cause Number 15606, in the 423rd Judicial District Court
of Bastrop County, Texas from January 13, 2015 through January 14, 2015.
PRAYER
The State requests the court accept the late brief filed in this Cause.
Respectfully Submitted,
/s/ Philip L. Hall
Philip L. Hall
Criminal District Attorney’s Office
Bastrop County Texas
804 Pecan Street
Bastrop, Texas 78602
State Bar Number 00787626
Phone: 512 581-7125
Fax: 512 581-7133
phil.hall@co.bastrop.tx.us
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the State’s Motion to File
Brief Late was mailed to Dal Ruggles, 1103 Nueces Street, Austin, Texas 78701,
counsel for the appellant, by certified mail on January 15, 2015.
/s/ Philip L. Hall
Philip L. Hall