Active 20059078.1 1 

NO. 03-15-00270-CV 

__________________________________________________________________ 

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 

__________________________________________________________________ 

 Mysha Lubke 

BAKER BOTTS 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

ATTORNEY FOR APPELLANT

ACCEPTED

03-15-00270-CV

6042245

THIRD COURT OF APPEALS

AUSTIN, TEXAS

7/13/2015 3:21:38 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 7/13/2015 3:21:38 PM JEFFREY D. KYLE Clerk
Active 20059078.1 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. 
Active 20059078.1 3 

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

Mysha Lubke 

State Bar No. 24083423 

mysha.lubke@bakerbotts.com 

BAKER BOTTS L.L.P. 

98 San Jacinto Blvd., Suite 1500 

Austin, TX 78701 

Telephone: (512) 322-2500 

Facsimile: (512) 322-2501 

ATTORNEY FOR APPELLANT

SUZANNA ECKCHUM

 
Active 20059078.1 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 

Mysha Lubke