John Joseph Foster v. State ( 2015 )

ACCEPTED
03-14-00252-CR
5220549
THIRD COURT OF APPEALS
AUSTIN, TEXAS
5/8/2015 5:45:47 PM
JEFFREY D. KYLE
CLERK
NO. 03-14-00252-CR
FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
5/8/2015 5:45:47 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 FOR LEAVE TO FILE LATE 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
jlamarca@wilco.org
NO. 03-13-00252-CR
JOHN JOSEPH FOSTER § IN THE COURT OF APPEALS
§
vs. § FOR THE THIRD DISTRICT
§
THE STATE OF TEXAS § OFTEXAS
MOTION FOR LEAVE TO FILE LATE 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 for Leave to File Late Brief,
and in support of this motion, would respectfully show the following:
1. The State's current deadline for filing its Brief was May 1, 2015.
2. The State asked for and received three prior extensions for filing its
Brief
3. The undersigned Assistant County Attorney has numerous matters on
appeal in various stages in the Court 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.
THEREFORE, the State asks leave of this Court for 7 additional days to
file this Brief until May 8, 2015.
SIGNED this the 8th day ofMay, 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 COMPLIANCE
I certify that this motion contains a word count of 158 and this
complies with Tex. R. App. P. 9.4.
Is/ James J. LaMarca
JAMES J. LAMARCA
CERTIFICATE OF SERVICE
I certify that I have sent a true and correct copy of State's Brief to
Appellant's attorney of record, Kristen Jernigan, by electronic service at
Kristen@txcrimapp.com, on the gth day ofMay, 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 for Leave to File Late 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 gth day of
May, 2015.
~i)
(
-
";'."' LISA A. ROBERTS
Notary Public, State of Tan
My Commlallon Elpha
~.. APRIL 3, 2018