ACCEPTED
03-14-00595-CR
4151522
THIRD COURT OF APPEALS
AUSTIN, TEXAS
2/13/2015 4:05:19 PM
JEFFREY D. KYLE
CLERK
No. 03-14-00595-CR
Court of Appeals FILED IN
3rd COURT OF APPEALS
FOR THE AUSTIN, TEXAS
Austin Supreme Judicial District 2/13/2015 4:05:19 PM
JEFFREY D. KYLE
Clerk
ANDREW ELON GARRAWAY,
Appellant
VS.
The State of Texas,
Appellee
Appeal From
The 22nd Judicial District Court
Hays County, Texas
Trial Court Cause Number CR-11 -0925
First Motion For Extension
of Time in Which to File State's Brief
Ben Moore
Asst. Criminal District Attorney
Hays County Government Center
712 South Stagecoach Trail, Ste. 2057
San Marcos, Texas, 78666
512-393-7600
benjamin.moore@co.hays.tx.us
State Bar No. 24042522
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 February 17,
2015.
2. This is the State's first Motion for Extension of Time in which to
file her brief
3. The State respectfully requests an extension of approximately
thirty days, until March 19, 2015 in which to file her brief
4. Good cause exists for the State's request for extension of time in
which to file its brief The undersigned attorney is currently responsible
for prosecuting over 170 felony cases and has not had adequate time to
devote to the proper research and drafting of the appellate reply 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 respectfully requests that the
Court grant an approximate thirty day extension for filing
Appellee's Brief, until March 19, 2015.
Respectfiilly submitted,
Ben Moore
Asst. Criminal District Attorney
Hays County Government Center
712 South Stagecoach Trail, Ste. 2057
San Marcos, Texas, 78666
512-393-7600
Benjamin.moore@co.hays.tx.us
State Bar No. 24042522
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 Ben Moore
on this the 13th of February, 2015.
Ben Moore
Notary Public in and for the State of Texas
CERTIFICATE OF CONFERENCE
I certify that I emailed Appellant's attorney Ellic Sahualla to ask if he
opposed the extension, on February 13, 2015. Mr. Sahualla repHed and has no
objection.
Ben Moore
CERTIFICATE OF SERVICE
I certify that on February 13, 2015,1 served the above motion by email
to ellic@sahuallalaw.com, in accordance with the Texas Rules of Appellate
Procedure.
Ben Moore