ACCEPTED
03-15-00270-CV
6042245
THIRD COURT OF APPEALS
AUSTIN, TEXAS
7/13/2015 3:21:38 PM
JEFFREY D. KYLE
CLERK
NO. 03-15-00270-CV
__________________________________________________________________
FILED IN
IN THE THIRD COURT OF APPEALS 3rd COURT OF APPEALS
AUSTIN, TEXAS
AUSTIN, TEXAS
7/13/2015 3:21:38 PM
__________________________________________________________________
JEFFREY D. KYLE
Clerk
SUZANNA ECKCHUM
Appellant,
v.
THE STATE OF TEXAS FOR THE PROTECTION OF HAL KETCHUM
Appellee.
__________________________________________________________________
ON APPEAL FROM THE COUNTY COURT AT LAW NO. 2
OF COMAL COUNTY
CAUSE NO. C2014-1690C
__________________________________________________________________
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
APPELLANT’S BRIEF
__________________________________________________________________
Mysha Lubke
BAKER BOTTS L.L.P.
State Bar No. 24083423
98 San Jacinto Blvd., Suite 1500
Austin, TX 78701
(512) 322-2500
(512) 322-2501 (fax)
mysha.lubke@bakerbotts.com
ATTORNEY FOR APPELLANT
Active 20059078.1 1
TO THE HONORABLE THIRD COURT OF APPEALS:
Appellant Suzanna Eckchum respectfully files this Unopposed Motion
for Extension of Time to File Appellant’s Brief, requesting that the time for filing
be extended to August 24, 2015, and in support, respectfully shows the Court the
following:
1. Currently, the Brief of Appellant is due on or before July 16, 2015.
2. This extension is necessary because undersigned appellate counsel
has requested that the court reporter supplement her record with
proceedings included in an earlier request for the reporter’s record.
It is possible that the reporter’s record will not be supplemented in
time to be adequately incorporated in the brief.
3. In addition, the demands of other litigation will prevent
undersigned counsel from working on the brief in the coming
weeks, including preparing for, traveling for, and trying a case in
Washington state the week of July 20, 2015.
4. Further, the undersigned counsel will be out of the country from
August 3, 2015 to August 13, 2015.
5. No previous extension has been requested or granted for this brief.
Active 20059078.1 2
6. This extension is not sought for purposes of delay, and the State
will not be prejudiced by this extension.
For these reasons, Appellant respectfully requests that this Court grant
a 40-day extension of time to file Appellant’s Brief, for a new deadline of August
24, 2015.
Respectfully submitted,
By: /s/ Mysha Lubke
Mysha Lubke
State Bar No. 24083423
mysha.lubke@bakerbotts.com
BAKER BOTTS L.L.P.
98 San Jacinto Blvd., Suite 1500
Austin, TX 78701
Telephone: (512) 322-2500
Facsimile: (512) 322-2501
ATTORNEY FOR APPELLANT
SUZANNA ECKCHUM
Active 20059078.1 3
CERTIFICATE OF CONFERENCE
I certify that on July 13, 2015, I spoke with Joshua Presley, an attorney at
the Comal County Criminal District Attorney’s office, regarding this motion for
extension of time, and he stated that the State does not oppose this motion.
/ s / Mysha Lubke
Mysha Lubke
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been served
by electronic filing and fax on July 13, 2015:
Counsel for the State of Texas for the Protection of Hal Ketchum:
The Honorable Jennifer A. Tharp
Comal County Criminal District Attorney
150 North Seguin, Suite 370
New Braunfels, Texas 78130
preslj@co.comal.tx.us
fax: 830-608-2008
/ s / Mysha Lubke
Mysha Lubke
Active 20059078.1 4