Chelsea Podowski v. State ( 2015 )

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