ACCEPTED
03-15-00340-CV
6965978
THIRD COURT OF APPEALS
AUSTIN, TEXAS
9/18/2015 3:27:08 PM
JEFFREY D. KYLE
03 CLERK
CAUSE NO. 01-15-00340-CV
IN THE COURT OF APPEALS FILED IN
3rd COURT OF APPEALS
FOR THE AUSTIN, TEXAS
THIRD JUDICIAL DISTRICT OF TEXAS9/18/2015 3:27:08 PM
AUSTIN, TEXAS JEFFREY D. KYLE
Clerk
______________________________________________________________________
CHRISTOPHER JAROSZEWICZ, APPELLANT
VS.
TEXAS DEPARTMENT OF PUBLIC SAFETY, APPELLEE
______________________________________________________________________
ON APPEAL FROM THE COUNTY COURT AT LAW NO. TWO
TRAVIS COUNTY, TEXAS
TRIAL COURT NO. C-1-CV-15-001468
SECOND MOTION FOR EXTENSION OF TIME
TO FILE APPELLANT’S BRIEF
_________________________________________________________________
KEVIN FINE
State Bar No. 00790682
P.O. Box 312
Boerne, Texas 78006
512-593-1383/Hill Country (ofc)
713-299-1923/Houston (cell)
888-803-8721
kfine@kevinfinelaw.com
ATTORNEY FOR APPELLANT
TO THE HONORABLE JUSTICES OF THE THIRD COURT OF APPEALS:
COMES NOW, Christopher Jaroszcewicz, Appellant in the above-styled and
numbered cause and, pursuant to TEX. R. APP. P. 10.5(b) and 38.6(d), files this
Second Motion to Extend Time to File Appellant's Brief, and with respect thereto,
would show the Court the following:
Appellant's Brief is currently due on September 16, 2015.
Counsel for Appellant requests a 30 day extension of time to file Appellant’s
Brief making the brief due on September 16, 2015. This is Appellant’s second
request for extension of time to file the opening brief.
Counsel for Appellant relies on the following reasons, in addition to the
routine matters that counsel must attend to in daily practice, to explain the need for
the requested extension.
Counsel has not received a copy of the Clerk’s file in this cause.
Additionally, counsel was hired on a federal case, within the last three weeks,
which originated out of the Western District of Illinois, and was then transferred to
the Western District of Texas. There have been two detention hearings in that
case, one in Chicago and the other in San Antonio. Counsel for Appellant seeks
this extension of time to be able to properly and thoroughly prepare Appellant’s
Brief. This request is not sought for delay, but so that justice may be done.
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PRAYER
WHEREFORE, PREMISES CONSIDERED, Appellant prays the Court
grant this motion.
RESPECTFULLY SUBMITTED,
__/s/ Kevin Fine_______________
KEVIN FINE
State Bar No. 00790682
P.O. Box 312
Boerne, Texas 78006
512-593-1383/Hill Country (ofc)
713-299-1923/Houston (cell)
888-803-8721
kfine@kevinfinelaw.com
ATTORNEY FOR APPELLANT
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above motion was
provided to the Travis County Attorney’s Office via efiling on this the 16th day of
September, 2015.
___/s/ Kevin Fine_____________
KEVIN FINE
CERTIFICATE OF CONFERENCE
I hereby certify that I made efforts to contact, but was unable to connect with
opposing counsel, Mr. Kevin Givens, in order to confer with him concerning
whether he has any objections to this motion.
SIGNED this the 18th day of August, 2015.
___/s/ Kevin Fine______________
KEVIN FINE
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Christopher Jaroszewicz v. Texas Department of Public Safety
Combined Opinion