ACCEPTED
03-14-00578-CR
4317473
THIRD COURT OF APPEALS
AUSTIN, TEXAS
2/27/2015 3:02:10 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
2/27/2015 3:02:10 PM
JEFFREY D. KYLE
THE STATE OF TEXAS Clerk
APPELLANT’S SECOND 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 Second 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 Monday, March 2, 2015.
IV.
This is Appellant’s second motion for extension of time to file his brief.
1
Appellant respectfully requests a forty-five day extension of time to file the brief, which
would make such brief due on Thursday, April 16, 2015.
V.
The undersigned attorney has been unable to complete the brief due to lack of
time. Counsel has completed review and research associated with his case and is the
process of drafting his brief. He has not been able to devote sufficient time to complete
the brief however due to a heavy workload that includes numerous cases and appeals in
several counties. 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 27th day of
February, 2015.
_/s/_Dal Ruggles____________
DAL RUGGLES
2