ACCEPTED

03-14-00194-CV

3711804

THIRD COURT OF APPEALS

AUSTIN, TEXAS

1/9/2015 11:53:37 AM

JEFFREY D. KYLE

CLERK

IN THE THIRD COURT OF APPEALS 

FOR THE STATE OF TEXAS 

TEXAS DEPARTMENT OF PUBLIC SAFETY 

v. NO. 03-14-00194-CV 

C.L. 

MOTION FOR EXTENSION OF TIME TO FILE APPELLEE'S BRIEF 

TO THE HONORABLE JUSTICES OF THE THIRD COURT OF APPEALS: 

COMES NOW, Amber D. Farrelly, and files this her Motion for Extension ofTime 

to File Appellee's Brief, pursuant to Rules 9 and 10 of the Texas Rules of Appellate 

Procedure, and in support thereof, would show the Court the following: 

I. 

On October 2, 2013, an Administrative License Revocation hearing was heard 

styled Texas Department of Public Safety v. Cody Littlepage at The State Office of 

Administrative Hearings. Littlepage's license was suspended for 180 days on 

October 3, 2013. Counsel for Littlepage filed an appeal on October 23, 2013. On 

February 6, 2014, a hearing on the appeal was held in County Court at Law Number 2 in 

Williamson County, Texas, cause number 13-1544-CC2. The appeal was granted and the 

case was reversed and remanded on February 28, 2014. On March 28, 2014, The 

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 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 1/9/2015 11:53:37 AM JEFFREY D. KYLE Clerk
Department appealed and requested the Reporter's Record. On Apri116, 2014, Counsel 

for Littlepage received notice that the one-volume clerk's record was filed. 

II. 

On November 12, 2014, Counsel for Littlepage received a notice from the Third 

Court stating that Appellee's brief was due on January 10, 2015. 

III. 

Appellant's attorney has been involved in three day jury trials in Travis County 

and Williamson County, including but not limited to, Lehr, Stephen (November 19-21, 

2014), Markowski, Daniel (November 24-26, 2014), Trejo, Michael (January 5-7), 2014, 

and is scheduled to start a five day felony jury trial in Travis County for Rocha, John 

(January 12-16, 2015). Appellant's attorney was asked to present a three day workshop 

in Colorado Springs, Colorado (December 4-6, 2014). Accordingly, counsel seeks two 

weeks of additional time to file her brief. 

PRAYER 

Wherefore, premises considered, undersigned counsel prays for this Court to 

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extend the time for filing Appellee's brief as 14 days from January 10, which would make 

the brief due on Friday January 23, 2015. 

Respectfully submitted, 

Austin, Texas 78745 

(512) 804-5911 

(512) 804-5919 fax 

SBN # 24069671 

By affixing my signature above, I, AMBER D. FARRELLY, hereby certify that a 

true copy of Motion for Extension of Time to File Appellant's Brief has been delivered 

to the Department ofPublic Safety on this day, January 9, 2015. 

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CERTIFICATE OF CONFERENCE 

As required by Texas Rule of Appellate Procedure lO.l{a)(S), I certify that I 

have conferred, or made a reasonable attempt to confer, with all other parties 

(which are listed below) about the merits of this motion with the following 

results: 

Department of Public Safety 

• Opposes motion 

fQ Does not oppose motion 

• Agrees with motion 

• Would not say whether motion is opposed 

• Did not return my message regarding the motion 

Attorney at Law 

Date