Ex Parte Ray Louis Johnson, Jr.

ACCEPTED
06-14-00214-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
2/24/2015 5:51:51 PM
DEBBIE AUTREY
CLERK
APPELLATE CAUSE NO. 06-14-00214-CR
TRIAL COURT CAUSE NOS. 0317178, 0317179, 0317180
§ IN THE COURT OF APPEALS
§
EX PARTE RAY LOUIS § SIXTH APPELLATE DISTRICT
JOHNSON, JR. §
§
§ TEXARKANA, TEXAS
02/24/2015
APPLICANT’S UNOPPOSED MOTION FOR LEAVE
TO FILE APPLICANT’S BRIEF OUT OF TIME
Applicant, by and though his counsel, files the above-referenced motion, and
for good cause shows the following:
1. Applicant’s Brief is ready for filing, right now, in the above-styled and
numbered cause. However, the deadline for that brief, February 17, 2015, has passed.
2. Counsel for Applicant cites his workload as to why Applicant’s Brief
was not timely filed. Counsel for Applicant represents 19 plaintiffs in a
misclassification case that is brought pursuant to the Fair Labor Standards Act. That
action is brought against two defendants. Counsel for Applicant filed a brief against
one of the defendants on Thursday, February 19, 2015, and counsel filed another brief
against the other defendant on the evening of Sunday, February 22, 2015.
3. Counsel for Applicant has conferred by telephone with the Office of the
District Attorney – specifically, Mr. Clay Harrison, who has been tasked with
representing the State in this matter. Attorney Harrison advised that the requested
relief is unopposed.
APPLICANT’S UNOPPOSED MOTION FOR LEAVE -PAGE 1-
TO FILE APPLICANT’S BRIEF OUT OF TIME
WHEREFORE, PREMISES CONSIDERED, Applicant prays that this Court
grant Applicant’s Unopposed Motion For Leave to File Applicant’s Brief Out of
Time, and for such other and further relief as the Court may deem appropriate.
Dated February 24, 2015
Respectfully submitted,
/s/ Wade A. Forsman
By:
Wade A. Forsman
State Bar No. 07264257
P.O. Box 918
Sulphur Springs, Texas 75483-0918
Tel: 903.689.4144
Fax: 903.689.7001
wade@forsmanlaw.com
Attorney for Applicant Ray Louis Johnson,
Jr.
CERTIFICATE OF SERVICE
This is to certify that on February 24, 2015, a true and correct copy of the
above and foregoing document was served on the Office of the District Attorney for
the 8th Judicial District, which is handling this matter, by email.
/s/ Wade A. Forsman
Wade A. Forsman
APPLICANT’S UNOPPOSED MOTION FOR LEAVE -PAGE 2-
TO FILE APPLICANT’S BRIEF OUT OF TIME
UNSWORN DECLARATTION
1. My name is Wade A. Forsman. I am the attorney whom the trial court
appointed to represent the applicant in this appeal.
2. All of the allegations of fact contained in the foregoing motion are true
and correct.
3. Pursuant to §132.001 of the Texas Civil Practice and Remedies Code,
my full name is Wade Arnold Forsman, my date of birth is June 14, 1958, my work
address is P.O. Box 918, Sulphur Springs, Hopkins County, Texas 75483-0918,
United States of America. I declare under penalty of perjury that the foregoing is true
and correct. Executed in Hopkins County, State of Texas, on the 24th day of February
2015.
/s/ Wade A. Forsman
Wade A. Forsman, Declarant
APPLICANT’S UNOPPOSED MOTION FOR LEAVE -PAGE 3-
TO FILE APPLICANT’S BRIEF OUT OF TIME