NO. 03-14-00252-CR 

IN THE COURT OF APPEALS 

FOR THE THIRD DISTRICT OF TEXAS 

AT AUSTIN 

JOHN JOSEPH FOSTER 

Appellant 

v. 

THE STATE OF TEXAS 

Appellee 

MOTION TO EXTEND TIME FOR FILING STATE'S 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 

j lamarca@wilco .org 

ACCEPTED

03-14-00252-CR

3973141

THIRD COURT OF APPEALS

AUSTIN, TEXAS

1/30/2015 4:44:39 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 1/30/2015 4:44:39 PM JEFFREY D. KYLE Clerk
NO. 03-14-00252-CR 

JOHN JOSEPH FOSTER § 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 January 30, 

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 at different stages in the various Courts of Appeals 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, 

respond to petitioners' writs of habeas corpus 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 current deadline of January 30, 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 30th day of January, 2015. 

Respectfully submitted, 

I sf 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 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 Kristen Jernigan, Appellant's 

attorney of record, by electronic service to Kristen@txcrimapp.com, on 

January 30, 2015. 

/s/ 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 to Extend Time for Filing State's Brief and swear that it 

is true base on my personal knowledge of the fact recited 

therein." 

s 

· ssistant County 

Williamson Cou 

This instrument was sworn to and subscribed before me, this the 30th day of 

January, 2015. 

~~~~¥,~ HOLlY BETH BOLTON f:"f--:.J..::.·i*~ Notary Public, State of Texas 

\~--~~i My Commission Expires ~-t',i!f:,.,. • DECEMBER 20, 2018