Cameron, Vanessa ( 2015 )

PD-1427-13 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 3/11/2015 7:22:07 PM March 12, 2015 Accepted 3/12/2015 8:56:36 AM ABEL ACOSTA No. PD-1427-13 CLERK IN THE TEXAS COURT OF CRIMINAL APPEALS VANESSA CAMERON, Petitioner, v. STATE OF TEXAS, Respondent. MOTION FOR LEAVE TO FILE REPONSE TO STATE’S REPLY TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS, SAN ANTONIO, TEXAS: NOW COMES, Petitioner, VANESSA CAMERON, by and through undersigned counsel files this motion for leave to file a Reply to the State’s Brief and in support of same would show the following: 1. On February 13, 2015 this Honorable Court notified Counsel that the Court would allow oral argument and further briefing on rehearing, for submission on March 18, 2015. 2. The State filed its Brief Following the Granting of Rehearing on Petition for Discretionary Review on February 20, 2015. 3. Undersigned counsel are filing their Reply Brief promptly to give this Honorable Court time to sufficiently review this Brief prior to submission. 1 WHEREFORE, PREMISES CONSIDERED, the Petitioner, Vanessa Cameron, respectfully prays that this Honorable Court grant this Motion for Leave to File a Reply to State’s Brief. Respectfully submitted: GERALD H. GOLDSTEIN Bar No. 08101000 DONALD H. FLANARY Bar No. 24045877 GOLDSTEIN, GOLDSTEIN AND HILLEY 310 S. St. Mary’s St. 29th Floor Tower Life Bldg. San Antonio, Texas 78205 210-226-1463 210-226-8367 facsimile JOHN T. HUNTER Bar No. 24077532 310 S. St. Mary’s St. Suite 1840- Tower Life Bldg. San Antonio, Texas 78205 210-399-8669 210-568-4927 facsimile By: /s/ Gerald H. Goldstein Gerald H. Goldstein Attorneys for Applicant, VANESSA CAMERON 2 CERTIFICATE OF SERVICE This is to certify that on March 11, 2015, a true and correct copy of the above and foregoing document was served on Jay Brandon, Assistant District Attorney at the Bexar County District Attorney’s Office, by electronic mail to jay.brandon@bexar.org. By: /s/ Gerald H. Goldstein Gerald H. Goldstein 3