Gayleen S. Todd v. State

Opinion

ACCEPTED 03-14-00386-CR 5613866 THIRD COURT OF APPEALS AUSTIN, TEXAS 6/10/2015 9:49:15 AM JEFFREY D. KYLE CLERK NO. 03-14-00386-CR

FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 6/10/2015 9:49:15 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

GA YLEEN 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 Brief is June 17,2015.

2. This is the State's first request for an extension of time.

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.

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 cuiTent deadline of June 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 9th day of June, 2014.

Respectfully submitted,

R ANPALMQUIST Assistant County Attorney Williamson County, Texas SBN: 24073307 405 Martin Luther King, # 7 Georgetown, Texas 78626 PI-lONE: (512) 943-1111 FAX: (512) 943-1120 CERTIFICATE OF SERVICE

I certifY that a true and correct 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 June 9, 2015. 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 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."

JityanPalmquist Assistant County Attorney Williamson County, Texas

This instrument was sworn to and subscribed before me, this the 9thth day of June, 2015.

ANNA ELIZABETH FAGAN Notary Public, State of Texas My Commission Expires AUGUST 12, 2018