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 [email protected]

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