Gayleen S. Todd v. State ( 2015 )

ACCEPTED
03-14-00386-CR
5974579
THIRD COURT OF APPEALS
AUSTIN, TEXAS
7/8/2015 10:19:13 AM
JEFFREY D. KYLE
CLERK
NO. 03-14-00386-CR
FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
7/8/2015 10:19:13 AM
JEFFREY D. KYLE
Clerk
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
GAYLEEN S. TODD § 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 Briefis July 17, 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 in various stages in the Comi 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 current deadline of July 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 8th day of July, 2015.
Respectfully submitted,
Y AN PALMQUIST
Assistant County Attorney
Williamson County, Texas
SBN: 24073307
405 Martin Luther King, # 7
Georgetown, Texas 78626
PHONE: (512) 943-1111
FAX: (512) 943-1120
CERTIFICATE OF SERVICE
I certifY that a true and conect 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 July 8, 2015 .
.~
RYAN PALMQUIST
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
L
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." ~
Ryan Palmquist
Assistant County Attorney
Williamson County, Texas
This instrument was sworn to and subscribed before me, this the gth day of July, 2015.
NOTARY PUBLIC
WANDA IVlCIC
Notary Public, State of Texas
My Commission Expires
DECEMBER 6, 2018