Angelita Rodriguez Pacheco v. State ( 2015 )

ACCEPTED 03-14-00676-CR 6153558 THIRD COURT OF APPEALS AUSTIN, TEXAS 7/21/2015 11:29:00 AM JEFFREY D. KYLE CLERK NO. 03-14-00676-CR RECEIVED IN 3rd COURT OF APPEALS AUSTIN, TEXAS IN THE COURT OF APPEALS 7/21/2015 11:29:00 AM FOR THE JEFFREY D. KYLE THIRD SUPREME JUDICIAL DISTRICT Clerk AT AUSTIN, TEXAS ANGELITA RODRIGUEZ PACHECO, Appellant vs. THE STATE OF TEXAS, Appellee Appeal from the 424th Judicial District Court Cause No. 41988 Burnet County, Texas The Honorable Dan Mills, Judge Presiding APPELLANT’S NOTICE OF LATE BRIEF Gary E. Prust State Bar No. 24056166 1607 Nueces Street Austin, Texas 78701 (512) 469-0092 Fax: (512) 469-9102 gary@prustlaw.com ATTORNEY FOR APPELLANT Oral Argument is not requested. APPELLANT’S NOTICE OF LATE BRIEF Now comes Appellant, by and through her attorney, Gary E. Prust, and files this Notice of Late Brief. Appellant’s brief was due July 20, 2015, and Appellant has been granted three requests for extension of time in which to file her brief. Attorney for Appellant has been diligently preparing, researching, and has narrowed the arguable issues. He has been unable to thoroughly and adequately complete the brief by the submission deadline but continues to dedicate a good deal of time to it. Attorney for Appellant has had an unexpected death in his immediate family in June and had to attend to those personal matters. Attorney for Appellant must also submit a brief in an unrelated appeal Wednesday, July 22, 2015 and anticipates that filing will be timely. Appellant will submit a completed brief by Friday, July 24, 2015. Attorney for Appellant as not abandoned the brief or his representation of Appellant. Respectfully submitted, /s/ Gary E. Prust Gary E. Prust State Bar No. 24056166 1607 Nueces St. Austin, Texas 78701 (512)469-0092 Fax (512)469-9102 gary@prustlaw.com Attorney for Appellant CERTIFICATE OF SERVICE In compliance with Rule 9.5(d) of the Texas Rules of Appellate Procedure, the undersigned attorney certifies that a true and correct copy of the foregoing Brief was served upon Mr. Blake Ewing and Mr. Gary Bunyard, Assistant District Attorneys for the 33rd and 424th Judicial District Attorney’s Office office via electronic transmission through efiletexas.gov on this 21st day of July, 2015. /s/ Gary Prust Gary E. Prust CERTIFICATE OF COMPLIANCE I hereby certify the above and foregoing Notice contains 156 words and is in compliance with TEX. R. APP. PROC. 9.4(2)(B). /s/ Gary Prust Gary E. Prust