Ramon M. Perez v. State ( 2015 )

ACCEPTED
05-14-01196-CR
FIFTH COURT OF APPEALS
DALLAS, TEXAS
10/7/2015 11:09:34 AM
LISA MATZ
CLERK
NO. 05-14-01196-CR
RAMON M. PEREZ § IN THE COURT OF APPEALS
FILED IN
5th COURT OF APPEALS
DALLAS, TEXAS
vs. § FOR THE FIFTH
10/7/2015DISTRICT
11:09:34 AM
LISA MATZ
THE STATE OF TEXAS § Clerk
OF TEXAS AT DALLAS
STATE’S MOTION TO PRESENT ORAL ARGUMENT
TO THE HONORABLE JUDGES OF SAID COURT:
THE STATE OF TEXAS, by and through the Criminal District Attorney of
Dallas County, and files this motion pursuant to Tex. R. App. P. 39.1 and requests oral
argument. In support of this motion the State shows the following:
Appellant requested oral argument on the front cover of his brief. The State was
represented by G. Brian Garrison at the time the State’s response to the appellant’s
brief was filed. Oral argument was waived by the State at that time.
Since the filing of the State’s response brief, undersigned counsel was assigned
to the above-referenced cause in the place of Mr. Garrison, who is no longer with the
District Attorney’s Office. Undersigned counsel has reviewed the briefs and record in
the above-referenced cause and requests the opportunity to respond to the appellant’s
oral argument.
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WHEREFORE, PREMISES CONSIDERED, and pursuant to Tex. R. App. P.
39.1, the State respectfully asks this Court to grant the State’s motion and allow the
State to participate in oral argument.
Respectfully submitted,
SUSAN HAWK /s/ Rebecca D. Ott
Criminal District Attorney Rebecca D. Ott
Dallas County, Texas Assistant District Attorney
Appellate Division
133 N. Riverfront Boulevard, LB-19
Dallas, Texas 75207-4399
(214) 653-3829
(214) 653-3643FAX
State Bar No. 24074842
rebecca.ott@dallascounty.org
CERTIFICATE OF SERVICE
I certify that a true copy of this motion has been served on the Hon. Ronald L.
Goranson, counsel for Appellant, by utilizing the electronic service function of the
Texas courts e-filing system on October 7, 2015.
//s/ Rebecca D. Ott
Rebecca D. Ott
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