Case Information
*0 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 7/13/2015 3:21:38 PM JEFFREY D. KYLE Clerk NO. 03-15-00270-CV THIRD COURT OF APPEALS 7/13/2015 3:21:38 PM JEFFREY D. KYLE AUSTIN, TEXAS 03-15-00270-CV *1 ACCEPTED [6042245] CLERK __________________________________________________________________
IN THE THIRD COURT OF APPEALS AUSTIN, TEXAS __________________________________________________________________
SUZANNA ECKCHUM Appellant, v.
THE STATE OF TEXAS FOR THE PROTECTION OF HAL KETCHUM
Appellee.
__________________________________________________________________
ON APPEAL FROM THE COUNTY COURT AT LAW NO. 2
OF COMAL COUNTY CAUSE NO. C2014-1690C __________________________________________________________________
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
APPELLANT’S BRIEF __________________________________________________________________
B AKER B OTTS L.L.P.
State Bar No. 24083423 98 San Jacinto Blvd., Suite 1500 Austin, TX 78701 (512) 322-2500 (512) 322-2501 (fax) mysha.lubke@bakerbotts.com A TTORNEY FOR A PPELLANT *2 TO THE HONORABLE THIRD COURT OF APPEALS:
Appellant Suzanna Eckchum respectfully files this Unopposed Motion
for Extension of Time to File Appellant’s Brief, requesting that the time for filing
be extended to August 24, 2015, and in support, respectfully shows the Court the
following:
1. Currently, the Brief of Appellant is due on or before July 16, 2015.
2. This extension is necessary because undersigned appellate counsel
has requested that the court reporter supplement her record with
proceedings included in an earlier request for the reporter’s record.
It is possible that the reporter’s record will not be supplemented in
time to be adequately incorporated in the brief.
3. In addition, the demands of other litigation will prevent
undersigned counsel from working on the brief in the coming
weeks, including preparing for, traveling for, and trying a case in
Washington state the week of July 20, 2015.
4. Further, the undersigned counsel will be out of the country from
August 3, 2015 to August 13, 2015.
5. No previous extension has been requested or granted for this brief.
6. This extension is not sought for purposes of delay, and the State
will not be prejudiced by this extension.
For these reasons, Appellant respectfully requests that this Court grant
a 40-day extension of time to file Appellant’s Brief, for a new deadline of August
24, 2015.
Respectfully submitted, By: /s/ Mysha Lubke State Bar No. 24083423 mysha.lubke@bakerbotts.com B AKER B OTTS L.L.P. 98 San Jacinto Blvd., Suite 1500 Austin, TX 78701 Telephone: (512) 322-2500 Facsimile: (512) 322-2501 A TTORNEY FOR A PPELLANT S UZANNA E CKCHUM *4 CERTIFICATE OF CONFERENCE I certify that on July 13, 2015, I spoke with Joshua Presley, an attorney at
the Comal County Criminal District Attorney’s office, regarding this motion for
extension of time, and he stated that the State does not oppose this motion.
/ s / Mysha Lubke Mysha Lubke CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been served
by electronic filing and fax on July 13, 2015:
Counsel for the State of Texas for the Protection of Hal Ketchum:
The Honorable Jennifer A. Tharp
Comal County Criminal District Attorney
150 North Seguin, Suite 370
New Braunfels, Texas 78130
preslj@co.comal.tx.us
fax: 830-608-2008
/ s / Mysha Lubke