Case Information
*0 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 1/30/2015 4:44:39 PM JEFFREY D. KYLE Clerk NO. 03-14-00252-CR THIRD COURT OF APPEALS 1/30/2015 4:44:39 PM JEFFREY D. KYLE 03-14-00252-CR AUSTIN, TEXAS *1 ACCEPTED [3973141] CLERK IN THE COURT OF APPEALS FOR THE THIRD DISTRICT OF TEXAS AT AUSTIN JOHN JOSEPH FOSTER Appellant v.
THE STATE OF TEXAS Appellee MOTION TO EXTEND TIME FOR FILING STATE'S BRIEF
Assistant County Attorney Williamson County, Texas State Bar No. 24074568 405 Martin Luther King,# 7 Georgetown, Texas 78626 PHONE: (512)943-1111 FAX: (512) 943-1120 j lamarca@wilco .org *2 NO. 03-14-00252-CR JOHN JOSEPH FOSTER § IN THE COURT OF APPEALS
§ 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 January 30,
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 at different stages in the various Courts of Appeals 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,
respond to petitioners' writs of habeas corpus 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 current deadline of January 30, 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 30th day of January, 2015.
Respectfully submitted, I sf James J. LaMarca Assistant County Attorney Williamson County, Texas SBN: 24074568 405 Martin Luther King,# 7 Georgetown, Texas 78626 PHONE: (512) 943-1111 FAX: (512) 943-1120 j lamarca@wilco.org *4 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 Kristen Jernigan, Appellant's
attorney of record, by electronic service to Kristen@txcrimapp.com, on
January 30, 2015.
/s/ James J. LaMarca *5 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 James J. LaMarca. 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."
s · ssistant County Williamson Cou This instrument was sworn to and subscribed before me, this the 30th day of
January, 2015.
~~~~¥,~ HOLlY BETH BOLTON f:"f--:.J..::.·i*~ Notary Public, State of Texas \~--~~i My Commission Expires ~-t',i!f:,.,. • DECEMBER 20, 2018