Question juridique clé
Whether the appellant's supplementary filing of 19 January 2009 could be considered despite expiry of the appeal period
Solution extraite
The supplementary filing could not be considered because it was submitted after the 30-day appeal period had expired.
Motifs extraits
Under Art. 100 para. 1 BGG, read with Arts. 44-48 BGG, the deadline ended on 12 January 2009; a late filing cannot cure defects in the complaint.