Foster, Ajah Marie

• Court: Court of Appeals of Texas
• Decided: July 28, 2015
• Docket: PD-0963-15
• Status: Published

Opinion

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