PD-1427-13
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
February 6, 2015 Transmitted 2/3/2015 6:36:59 PM
Accepted 2/6/2015 8:56:57 AM
No. PD-1427-13 ABEL ACOSTA
CLERK
IN THE TEXAS COURT OF CRIMINAL APPEALS
VANESSA CAMERON,
Petitioner
v.
STATE OF TEXAS,
Respondent.
SECOND MOTION FOR LEAVE TO FILE
ADDITIONAL BRIEFING ON REHEARING
(WITH BRIEF ATTACHED)
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:
COMES NOW VANESSA CAMERON, Petitioner in the above styled and numbered
cause, and by and through undersigned counsel, respectfully requests leave for filing Additional
Briefing on Rehearing and in response to Respondent’s Motion for Rehearing pursuant to Rule
70.4 of the Texas Rules of Appellate Procedure.
WHEREFORE, PREMISES CONSIDERED, Appellant prays this Court to grant oral
argument and to grant leave for the preparation and submission of additional briefing.
Respectfully submitted
Gerald H. Goldstein
State Bar No. 08101000
Donald H. Flanary, III
State Bar No. 24045877
Goldstein, Goldstein, & Hilley
29th Floor Tower Life Building
San Antonio, Texas 78205
210-226-1463, 210-226-8367 facsimile
John T. Hunter
State 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
Attorney for Vanessa Cameron
CERTIFICATE OF SERVICE
This is to certify that on February 3, 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
/s/ Gerald H. Goldstein
Gerald H. Goldstein