ACCEPTED
03-14-00578-CR
6527835
THIRD COURT OF APPEALS
AUSTIN, TEXAS
8/17/2015 3:29:19 PM
JEFFREY D. KYLE
CLERK
NO. 03-14-00578-CR
COURT OF APPEALS FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
FOR THE 8/17/2015 3:29:19 PM
JEFFREY D. KYLE
Clerk
THIRD SUPREME JUDICIAL DISTRICT
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
MOTION FOR LEAVE TO FILE UNTIMELY APPELLEE'S BRIEF
Whitney L. Borgman
Assistant Criminal District Attorney
712 S. Stagecoach Trail, Suite 2057
San Marcos, Texas 78666
ORAL ARGUMENT IS ph; (512) 393-7600 / Fax: (512) 393-2246
NOT REQUESTED state Bar No. 24082224
Whitney.borgnian@co.hays.tx.us
Attorney for the State of Texas
TO THE HONORABLE JUSTICES OF THE THIRD COURT OF APPEALS:
)
Now comes Appellee, the State of Texas, and files this Motion for Leave to
File an Untimely Appellee's Brief, and in support states the following:
1. Appellee's Brief was due on July 31, 2015.
2. Attorney for the Appellee, Whitney L. Borgman began working for the Hays
County District Attorney's Office on June 1, 2015 and attended CLE trainings
July 20-24, 2015 and August 5, 2015 and was out of the office.
3. This Motion is not sought for delay, but so justice may be served.
4. For the foregoing reason, the undersigned attorney hereby requests leave to
untimely files this Appellee's Brief pursuant to Texas Rules of Appellate
Procedure, Rule 38.6, which provides modifications of filing time.
Respectfully submitted,
Whitney L. BojJman
Asst. Criminal District Attorney
Hays County Government Center
712 S. Stagecoach Trail, Suite 2057
San Marcos, Texas 78666
Ph: (512) 393-7600/Fax: (512) 393-2246
State Bar No. 24082224
whitney.borgman@co.hays.tx.us
Attorney for the State of Texas
CERTIFICATE OF SERVICE
I herebycertifythat a true copy of the foregoing motion has been e-delivered
to:
Dal Ruggles
1103 Nueces
Austin, Texas 78701
dal@ruggleslaw.com
On this the 17th day of August, 2015.
litney L. Borgjnan
Asst. Criminal Sistrict Attorney