Key legal question
Whether the federal appeal was filed within the statutory deadline
Extracted holding
The appeal was filed out of time because the deadline expired on 2012-09-04 and the email and mailed submission of 2012-09-11 did not comply with filing requirements.
Extracted reasoning
The decision was served on 2012-07-04; the 30-day period ran from 2012-07-05 and, including the summer suspension, ended on 2012-09-04. An unencrypted email is not valid filing under Art. 48(2) BGG, and the mailed version arrived after the deadline.