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Texas Department of Public Safety v. Louis Leroy Kuhn
06-15-00083-CV
Tex. App.
Dec 8, 2015
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Case Information

*0 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 12/8/2015 3:49:50 PM DEBBIE AUTREY Clerk *1 ACCEPTED 06-15-00083-CV SIXTH COURT OF APPEALS TEXARKANA, TEXAS 12/8/2015 3:49:50 PM DEBBIE AUTREY CLERK NO. 06-15-00083-CV

IN THE COURT OF APPEALS

FOR THE SIXTH SUPREME JUDICIAL DISTRICT OF TEXAS

AT TEXARKANA TEXAS DEPARTMENT OF PUBLIC SAFETY § Appellant

V. §

LOUIS LEROY KUHN § Appellee

APPELLEE'S REQUEST FOR

EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE COURT OF APPEALS:

Counsel for Appellee requests an Extension of Time to File the Appellee's

Brief; the following is satisfied:

1. The trial court number is 15-0348C;

2. The County Court at Law of Hays County rendered judgment on August

11, 2015;

3. Notice of Appeal was filed by Appellant (Texas Department of Public

Safety) on September 10, 2015;

4. Appellant’s Brief was filed on November 9, 2015;

5. Appellee has only recently been capable of securing Appellee Counsel

and was retained by Appellee by and through the Trial Counsel on

December 1, 2015;

6. Counsel has since begun researching this matter, reviewing Appellant's

Brief, the record and the law. Counsel has not received a copy of the

Reporter’s Record, however is in the process of securing such.

Appellee prays that this Court grant an extension of sixty (60) days in order

to allow for the formal filing of Appellee’s Brief to consider this matter on it’s

merits. Respectfully submitted, Scot Courtney Attorney for Appellee P. O. Box 787 San Marcos, Texas 78667-0787 512-392-9292 512-532-6766 FAX State Bar #00790515 *3 CERTIFICATE OF SERVICE

By affixing his signature to the foregoing instrument, Scot Courtney certifies

that a true and correct copy of the same has been delivered via email to the offices

of the below-listed counsel, on this the 8th day of December, 2015.

! Scot Courtney Kevin M. Givens

Texas Department of Public Safety

Kevin.Givens@dps.texas.gov CERTIFICATE OF CONFERENCE

By affixing his signature to the foregoing instrument, Scot Courtney certifies

that Counsel has conferred with Appellate Counsel and Appellate Counsel, listed

below does not oppose the Motion.

Scot Courtney Kevin M. Givens

Texas Department of Public Safety

Kevin.Givens@dps.texas.gov *4 VERIFICATION STATE OF TEXAS §

COUNTY OF HAYS §

BEFORE ME, the undersigned authority on this day, personally appeared

Scot Courtney, who did depose and state as follows:

"My name is Scot Courtney. I have read the foregoing Motion. All facts

contained therein are true and correct."

Scot R. Courtney SWORN AND SUBSCRIBED to before me, the undersigned authority

on this the ______ day of ____________________, 2015.

________________________________

NOTARY PUBLIC IN AND FOR THE STATE OF TEXAS

Case Details

Case Name: Texas Department of Public Safety v. Louis Leroy Kuhn
Court Name: Court of Appeals of Texas
Date Published: Dec 8, 2015
Docket Number: 06-15-00083-CV
Court Abbreviation: Tex. App.
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