ACCEPTED
03-14-00595-CR
4634374
THIRD COURT OF APPEALS
AUSTIN, TEXAS
3/25/2015 11:14:14 AM
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 3/25/2015 11:14:14 AM
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 NO. CR-11-0925
MOTION FOR LEAVE TO FILE UNTIMELY STATE'S BRIEF
TO THE HONORABLE JUSTICES OF THE THIRD COURT OF
APPEALS:
State files this Motion for Leave to File an Untimely Brief, and in
support states:
1. The State's Brief was due on March 19, 2015.
2. The time to file the State's brief has expired. The undersigned
attorney was preparing for jury trial and due to a heavy case load, the brief
has taken longer than expected to finalize.
3. This Motion is not sought for delay but so that justice may be
done.
4. For the foregoing reasons, the State seeks leave to file this brief
late pursuant to Texas Rules of Appellate Procedure, Rule 38.6.
Respectfully submitted.
Ben Moore
Assistant Criminal District Attorney
Hays County, Texas
Hays County Government Center
712 South Stagecoach Trail, Ste. 2057
San Marcos, Texas 78666
benjamin.moore@co.hays.tx.us
(512)393-7600
(512) 393-2246 fax
State Bar No. 24042522
Counsel for State
CERTIFICATE
The foregoing Appellee Motion for Leave to File Untimely State's
Briefwas subscribed and sworn to before me by Ben Moore onthis the 25^
day of March, 2015.
Ben Moore
RHONDA WIEDERSTEIN
MY COMMISSION EXPIRES
September 9,2018
Notary Public in and for the State of Texas
CERTIFICATE OF SERVICE
I certify that on March 25, 2015 I served the above motion by email to
Ellic Sahualla at ellic@sahuallalaw.com.
Ben Moore
Andrew Garraway v. State
Combined Opinion