ACCEPTED
03-14-00252-CR
4338561
THIRD COURT OF APPEALS
AUSTIN, TEXAS
3/2/2015 4:11:28 PM
JEFFREY D. KYLE
CLERK
NO. 03-14-00252-CR
FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
3/2/2015 4:11:28 PM
JEFFREY D. KYLE
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
JAMES J. LAMARCA
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
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 March 2,
2015.
2. This is the State's second 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 March 2, 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 2nd day of March, 2015.
Respectfully submitted,
Is/ James J. LaMarca
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
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
March 2, 2015.
Is/ James J. LaMarca
JAMES J. LAMARCA
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."
This instrument was sworn to and subscribed before me, this the 2nd day of
March, 20 15.