ACCEPTED
03-15-00340-CV
6539616
THIRD COURT OF APPEALS
AUSTIN, TEXAS
8/18/2015 11:30:47 AM
03 CV
JEFFREY D. KYLE
CLERK
CAUSE NO. 01-15-00340-CR
IN THE COURT OF APPEALS FILED IN
3rd COURT OF APPEALS
FOR THE AUSTIN, TEXAS
THIRD JUDICIAL DISTRICT OF TEXAS8/18/2015 11:30:47 AM
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
______________________________________________________________________
APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE 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
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 August 17, 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 first
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 was not provided a copy of the Clerk’s Record and was only
recently provided a copy of the Reporter’s record in this case. 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.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Appellant prays the Court
grant this motion.
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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 18th day of
August, 2015.
___/s/ Kevin Fine_____________
KEVIN FINE
CERTIFICATE OF CONFERENCE
I hereby certify that I conferred with counsel for Appellee, Mr. Kevin
Givens, and he has no opposition to Appellant’s 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