ACCEPTED
03-14-00578-CR
5492498
THIRD COURT OF APPEALS
AUSTIN, TEXAS
6/1/2015 2:28:35 PM
JEFFREY D. KYLE
CLERK
NO. 03-14-00578-CR
COURT OF APPEALS FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
FOR THE
6/1/2015 2:28:35 PM
JEFFREY D. KYLE
AUSTIN SUPREME JUDICIAL DISTRICT Clerk
DANIEL RAYMOND VADNAIS,
Appellant
VS.
THE STATE OF TEXAS,
Appellee
APPEAL FROM
THE 22ND JUDICIAL DISTRICT COURT
HAYS COUNTY, TEXAS
TRIAL COURT CAUSE NO. CR-13-0651
First Motion For Extension
of Time in Which to File State's Brief
Whitney Borgman
Asst. Criminal District Attorney
712 S. Stagecoach Trail, Suite 2057
San Marcos, Texas 78666
Ph: (512) 878-6544/Fax: (512) 393-2246
State Bar No. 24082224
whitney.borgman@co.hays.tx.us
Attorney for the State of Texas
TO THE HONORABLE JUSTICES OF THE THIRD COURT OF
APPEALS:
The State files this First Motion for Extension of Time in Which to File
State's Brief, and in support states:
1. The State's current deadline for filing its brief is June 1, 2015.
2. This is the State's first Motion for Extension of Time in which to file
its brief.
3. The State respectfiilly requests an extension of approximately sixty
days, until July 31, 2015 in which to file its brief.
4. Good cause exists for the State's request for extension of time in which
to file its brief. The attorney of record delivered her child 7 weeks
prematurely. This office requests additional time for reassignment of
State's Brief.
5. These circumstances have significantly delayed the completion of this
brief.
6. This extension is not being sought to cause undue delay, but to seek
justice.
7. For the foregoing reasons, the State respectfiilly requests that the Court
grant an approximate sixty day extension for filing Appellee's Brief,
until July 31, 2015.
Respectfully submitted,
Whitney Bo^gjfian
Asst. Criminal District Attorney
Hays County Government Center
712 South Stagecoach Trail, Ste. 2057
San Marcos, Texas, 78666
512-878-6544
whitney.borgman@co.hays.tx.us
State Bar No. 24082224
Attorney for the State of Texas
The foregoing Appellant Motion for Extension of Time in Which to
File Appellant's Brief was subscribed and sworn to before me by Whitney
Borgman on this the 1st of June, 2015.
\^itney Borgmap (_
RHONDA WIEDERSTEIN
]*) MY COMMISSION EXPIRES
September 9,2018
Notary Public in and for the State of Texas
CERTIFICATE OF SERVICE
I certify that on June 1, 2015, I served the above motion by email to
Dal Ruggles at dal@ruggleslaw.com, in accordance with the Texas Rules of
Appellate Procedure.
Whitney Borgi^n /