Gayleen S. Todd v. State

03-14-00386-CR | Tex. App. | Jun 10, 2015

FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 6/10/2015 9:49:15 AM JEFFREY D. KYLE Clerk

ACCEPTED 03-14-00386-CR [5613866] THIRD COURT OF APPEALS AUSTIN, TEXAS 6/10/2015 9:49:15 AM JEFFREY D. KYLE CLERK NO. 03-14-00386-CR IN THE COURT OF APPEALS FOR THE THIRD DISTRICT OF TEXAS AT AUSTIN GAYLEEN S. TODD Appellant v.

THE STATE OF TEXAS Appellee MOTION TO EXTEND TIME FOR FILING STATE'S BRIEF RYAN PALMQUIST Assistant County Attorney Williamson County, Texas State Bar No. 24073307 405 Martin Luther King, # 7 Georgetown, Texas 78626 PHONE: (512) 943-1111 FAX: (512) 943-1120

NO. 03-14-00386-CR

§ IN THE COURT OF APPEALS

GA YLEEN S. TODD § vs.

§ FOR THE THIRD DISTRICT

§

THE STATE OF TEXAS

§ OFTEXAS

MOTION FOR EXTENSION OF TIME TO FILE STATE'S BRIEF

TO THE HONORABLE JUSTICES OF THE THIRD COURT OF APPEALS:

The State of Texas by and through its attorney, Dee Hobbs, Williamson County Attorney, files this Motion to Extend Time for Filing State's Brief, and in support of this motion, would respectfully show the following:

1. The State's current deadline for filing its State's Brief is June 17,2015. 2. This is the State's first request for an extension of time. 3. The undersigned Assistant County Attorney has numerous matters on

appeal in various stages in the Court of Appeals for the Third District of Texas. Furthermore, the undersigned Assistant County Attorney continues to be required in the courtroom to assist with dockets, to answer and research questions from law enforcement and other prosecutors, and represent applicants for protective orders. For the above-mentioned reasons, the undersigned Assistant County

Attorney has not had sufficient time to research the applicable law and prepare an adequate brief by the cuiTent deadline of June 17, 2015.

THEREFORE, the State requests that the Court grant this motion and extend the deadline for filing the brief of Appellee for thirty (30) days beyond the original deadline imposed.

SIGNED this the 9th day of June, 2014. Respectfully submitted,

R ANPALMQUIST

Assistant County Attorney Williamson County, Texas

SBN: 24073307

405 Martin Luther King, # 7 Georgetown, Texas 78626 PI-lONE: (512) 943-1111

FAX: (512) 943-1120

CERTIFICATE OF SERVICE

I certifY that a true and correct copy of this State's Motion to Extend Time for Filing State's Brief was served upon Gayleen S. Todd, Appellant, by certified mail, on June 9, 2015.

AFFIDAVIT OF VERIFICATION

BEFORE ME, Notary Public in and for the State and County aforesaid, on this day personally appeared the undersigned affiant who, after being duly sworn, deposes and says the following:

"My name is Ryan Palmquist. I am an Assistant County Attorney for Williamson County, Texas. I have read the above Motion to Extend Time for Filing State's Brief and swear that it is true base on my personal knowledge of the fact recited therein."

JityanPalmquist Assistant County Attorney Williamson County, Texas

This instrument was sworn to and subscribed before me, this the 9thth day of June, 2015.

ANNA ELIZABETH FAGAN

Notary Public, State of Texas

My Commission Expires

AUGUST 12, 2018