ACCEPTED
06-15-00083-CV
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
12/8/2015 3:49:50 PM
DEBBIE AUTREY
CLERK
NO. 06-15-00083-CV
FILED IN
IN THE COURT OF APPEALS 6th COURT OF APPEALS
TEXARKANA, TEXAS
12/8/2015 3:49:50 PM
FOR THE DEBBIE AUTREY
Clerk
SIXTH SUPREME JUDICIAL DISTRICT OF TEXAS
AT TEXARKANA
TEXAS DEPARTMENT OF PUBLIC SAFETY § Appellant
V. §
LOUIS LEROY KUHN § Appellee
APPELLEE'S REQUEST FOR
EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE COURT OF APPEALS:
Counsel for Appellee requests an Extension of Time to File the Appellee's
Brief; the following is satisfied:
1. The trial court number is 15-0348C;
2. The County Court at Law of Hays County rendered judgment on August
11, 2015;
3. Notice of Appeal was filed by Appellant (Texas Department of Public
Safety) on September 10, 2015;
4. Appellant’s Brief was filed on November 9, 2015;
5. Appellee has only recently been capable of securing Appellee Counsel
and was retained by Appellee by and through the Trial Counsel on
December 1, 2015;
6. Counsel has since begun researching this matter, reviewing Appellant's
Brief, the record and the law. Counsel has not received a copy of the
Reporter’s Record, however is in the process of securing such.
Appellee prays that this Court grant an extension of sixty (60) days in order
to allow for the formal filing of Appellee’s Brief to consider this matter on it’s
merits.
Respectfully submitted,
!
Scot Courtney
Attorney for Appellee
P. O. Box 787
San Marcos, Texas 78667-0787
512-392-9292
512-532-6766 FAX
State Bar #00790515
CERTIFICATE OF SERVICE
By affixing his signature to the foregoing instrument, Scot Courtney certifies
that a true and correct copy of the same has been delivered via email to the offices
of the below-listed counsel, on this the 8th day of December, 2015.
!
Scot Courtney
Kevin M. Givens
Texas Department of Public Safety
Kevin.Givens@dps.texas.gov
CERTIFICATE OF CONFERENCE
By affixing his signature to the foregoing instrument, Scot Courtney certifies
that Counsel has conferred with Appellate Counsel and Appellate Counsel, listed
below does not oppose the Motion.
!
Scot Courtney
Kevin M. Givens
Texas Department of Public Safety
Kevin.Givens@dps.texas.gov
VERIFICATION
STATE OF TEXAS §
COUNTY OF HAYS §
BEFORE ME, the undersigned authority on this day, personally appeared
Scot Courtney, who did depose and state as follows:
"My name is Scot Courtney. I have read the foregoing Motion. All facts
contained therein are true and correct."
!
Scot R. Courtney
SWORN AND SUBSCRIBED to before me, the undersigned authority
on this the ______ day of ____________________, 2015.
________________________________
NOTARY PUBLIC IN AND FOR
THE STATE OF TEXAS