Foster, Ajah Marie ( 2015 )

PD-0963-15 PD-0963-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 7/24/2015 2:50:37 PM
Accepted 7/28/2015 1:43:11 PM
TO THE COURT OF CRIMINAL APPEALS ABEL ACOSTA
CLERK
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 Motion To Extend Time
To File Petition For Discretionary Review
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:
COMES NOW, AJAH FOSTER, and files this her 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 Foster v. State, 14-13-
01068-CR, 2015 WL 3631689, at *1 (Tex. App.—Houston [14th Dist.] June 11, 2015) No
motion for rehearing was filed. No other motions for extension have 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 July 13, 2015. Appellant
requests this extension due to the fact that counsel for Appellant has been engaged in work in
the Harris County Public Defender’s Office on many cases, including the following:
 Ruben Totten, PD-0483-15
 Domingo Medina, 01-15-00574-CR
 Kori Henegar, 14-15-00529-CR
 Trey Foster, 14-15-00496-CR
 Hugo Pachas-Luna, 01-14-00516-CR - 01-14-00520-CR
 Rodney Robins, 01-14-00582-CR
 Stephen Hopper, 14-15-00371-CR
July 28, 2015
 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 for 30 days, to August 24, 2015.
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
Attorney for Appellant
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
Sarah V. Wood