Chelsea Podowski v. State

ACCEPTED 03-15-00109-CR 7809662 THIRD COURT OF APPEALS AUSTIN, TEXAS 11/12/2015 5:21:05 PM JEFFREY D. KYLE CLERK NO. 03-15-00109 CHELSEA PODOWSKI § IN THE THIRD FILED COURT IN 3rd COURT OF APPEALS AUSTIN, TEXAS V. § OF APPEALS 11/12/2015 5:21:05 PM JEFFREY D. KYLE THE STATE OF TEXAS § IN AUSTIN, TEXAS Clerk APPELLANT’S THIRD MOTION TO EXTEND TIME TO FILE REPLY TO APEELLEE’S BRIEF COMES NOW Chelsea Podowski, Appellant in the above-styled and numbered cause, by and through his undersigned counsel, and respectfully moves this Court to extend the time to file Appellant’s brief. In support thereof, and pursuant to TEX. R. APP. PROC. 10.5(b), Appellant would show as follows: (A) Appellant’s Reply to Appellee’s Brief is due on November 9, 2015; (B) Appellant seeks a 3 day extension until November 12, 2015; (C) Undersigned counsel delivered the Reply brief on time to opposing counsel. However, when attempting to e-file, the electronic envelope was not finalized until the next morning, on November 10th. The Court’s Clerk also requested counsel to amend the delivered reply by including a certificate of compliance by November 12, 2015. No other changes have been made to the brief submitted on November 10, 2015 other than the requested certificate of compliance has been included in the amended brief filed on November 12, 2015. WHEREFORE, PREMISES CONSIDERED, Appellant prays that the foregoing motion be GRANTED. Respectfully submitted, ________/s/ James Gill_______ JAMES GILL 1201 Rio Grande Street, Ste. 200 Austin, Texas 78701 (512) 448-4560 (512) 308-6780 (Fax) jgill@austin-criminallawyer.com State Bar No. 24043692 ATTORNEY FOR APPELLANT CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Appellant’s Third Motion to Extend Time to File Reply Brief was served on the Travis County District Attorney, P.O. Box 1748, Austin, Texas, 78767, by electronic transmission (TCAppellate@traviscountytx.gov) and the Court of Appeals, on this the 12th day of November 2015. ________/s/ James Gill_______ JAMES GILL