ACCEPTED
03-14-00578-CR
4721799
THIRD COURT OF APPEALS
AUSTIN, TEXAS
4/1/2015 9:43:43 AM
JEFFREY D. KYLE
CLERK
IN THE THIRD COURT OF APPEALS
FOR THE STATE OF TEXAS
FILED IN
3rd COURT OF APPEALS
DANIEL VADNAIS AUSTIN, TEXAS
4/1/2015 9:43:43 AM
V. NO. JEFFREY
03-14-00578-CR
D. KYLE
Clerk
THE STATE OF TEXAS
APPELLANT’S THIRD 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 Third 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
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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
Wednesday, April 1, 2015.
IV.
This is Appellant’s third motion for extension of time to file his brief.
Appellant respectfully requests a thirty day extension of time to file the brief,
which would make such brief due on Friday, May 1, 2015.
V.
The undersigned attorney has been unable to complete the brief due to lack
of time. Counsel has completed his review of the record and the research
associated with several legal issues in his case and is the process of drafting his
brief. He has not been able to devote sufficient time to complete the final draft
however due to a demanding workload that includes numerous cases and
appeals in several counties. Counsel is currently working on four felony
appeals, two of which are due within the next week, and one misdemeanor
appeal that will possibly require a hearing on a motion for new trial. Counsel’s
active caseload beyond appellant work includes approximately thirty-five cases
in three different counties. For this reason the undersigned attorney asks that
this extension be granted so that he may devote the additional time necessary to
effectively represent Appellant and so that justice may be done in this case.
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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 Third 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
1st day of April, 2015.
_/s/_Dal Ruggles____________
DAL RUGGLES
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