Foster, Ajah Marie

PD-0963-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 8/27/2015 10:19:47 PM Accepted 8/28/2015 12:10:29 PM NO. PD-0963-15 ABEL ACOSTA CLERK TO THE COURT OF CRIMINAL APPEALS FROM THE FOURTEENTH COURT OF APPEALS NO. 14-13-01068-CR AJAH FOSTER APPELLANT On Appeal from Cause Number 1388752 From the 184th District Court of Harris County V. THE STATE OF TEXAS APPELLEE Appellant’s FINAL Motion To Extend Time To File Petition For Discretionary Review Accompanied by PDR TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS: COMES NOW, AJAH FOSTER, and files this her Final Motion to Extend Time to File Petition for Discretionary Review, and in support thereof, would respectfully show the Court the following: I. The Fourteenth Court of Appeals affirmed the trial court’s judgment in an unpublished opinion. Foster v. State, 14-13-01068-CR, 2015 WL 3631689 (Tex. App.—Houston [14th Dist.] June 11, 2015, no. pet. h.). One other motion for extension has been filed. II. In compliance with Texas Rule of Appellate Procedure 68.2(c), this motion for extension is timely filed within 15 days of the deadline for the PDR, which was August 12, 2015. Appellant requests this extension due to the fact that counsel for Appellant has been suffering from a chronic illness, has been out of the office on family business for approximately two weeks and additionally has been engaged in work in the Harris County Public Defender’s Office on many cases, including the following:  Jeremy Thomas, PD-1086-15  Felix Irizarry, 14-14-00827-CR  Domingo Medina, 01-15-00575-CR  Leonard Storemski, 14-14-00921-CR August 28, 2015  Hugo Pachas-Luna, 01-14-00516-CR - 01-14-00520-CR  Stephen Hopper, 14-15-00371-CR  Pete Rodriguez, 14-15-00339-CR  Vincent Williams, 14-15-00220-CR  Darryle Robertson, 14-15-00132-CR  Counsel has been researching and writing for several trial cases assigned to the Public Defender’s Office Trial Division. III. Appellant’s attorney requests this brief extension which is necessary so that the petition can be thoroughly written and timely filed. This motion is not made for the purpose of delay. PRAYER WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable Court grants this requested extension of time to file the appellant’s petition for discretionary review in the above cause and extend the time for filing to the day on which the PDR is simultaneously submitted or the official date it is deemed filed. Respectfully submitted, ALEXANDER BUNIN Chief Public Defender Harris County, Texas /s/Sarah V. Wood SARAH V. WOOD Assistant Public Defender Harris County, Texas Texas Bar Number 24048898 1201 Franklin, 13th Floor Houston Texas 77002 713.368.0016 (phone) 713.368.9278 (fax) Sarah.Wood@pdo.hctx.net CERTIFICATE OF SERVICE By my signature below, I hereby certify that a true and correct copy of the above and foregoing Appellant’s Motion to Extend Time to File Petition for Discretionary Review has been served on the District Attorney of Harris County, Texas, by electronic delivery through the efile system. /s/Sarah V. Wood