ACCEPTED
03-14-00068-CV
3865786
THIRD COURT OF APPEALS
AUSTIN, TEXAS
1/22/2015 3:13:29 PM
JEFFREY D. KYLE
CLERK
APPEAL NO. 03-14-00068-CV
FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
COURT OF APPEALS FOR THE THIRD DISTRICT1/22/2015
OF TEXAS3:13:29 PM
JEFFREY D. KYLE
AUSTIN, TEXAS Clerk
LARRY MARK POLSKY, APPELLANT
VS.
THE STATE OF TEXAS, APPELLEE
__________________________________________________________________
APPEAL FROM CAUSE NO. D-1-GV-13-000067
IN THE 126TH DISTRICT COURT OF TRAVIS COUNTY, TEXAS
__________________________________________________________________
APPELLANT’S MOTION FOR PERMISSION TO FILE ADDITIONAL
AUTHORITY
_________________________________________________________________
TO THE HONORABLE THIRD COURT OF APPEALS:
COMES NOW, Appellant, Larry Mark Polsky, Esq., and hereby requests
this Honorable Court for leave to file additional authority and would show as
follows:
1. Attached as Exhibit “A” are the applicable pages are the current Cameron
County Beach Access and Dune Protection Plan.
2. That the main thrust of Polsky’s appeal is that Javier Mendez who is the
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Parks and Recreation Director of Cameron County was the sole
individual who would report “alleged” violations of Polsky’s dune
protection permit to the Cameron County Commissioners.
3. That the attached “authority” supports Polsky’s position as to this portion
of his argument.
WHEREFORE, Larry Mark Polsky, Esq. respectfully requests this
Honorable Court to allow him to file the attached additional authority which was
previously filed as “Notice of Additional Authority.”
Please govern yourselves accordingly.
/s/ Larry Mark Polsky, Esq.
LARRY MARK POLSKY, ESQ.
State Bar No. 16105500
Law Office of Larry Mark Polsky
5508 Padre Blvd.
South Padre Island, Texas 78597
(956) 761-1529 Telephone
(956) 761-1599 Facsimile
CERTIFICATE OF CONFERENCE
I certify that I have previously emailed Shelly Doggett, Esq. and informed
her that I would be filing the above “Notice of Additional Authority.” Ms. Doggett
has not emailed me back to date stating whether or not she objects to same.
/s/ Larry Mark Polsky, Esq.
LARRY MARK POLSKY, ESQ.
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CERTIFICATE OF SERVICE
I certify that the original of this document was served on the Third Court of
Appeals in Austin, Texas for filing by e-filing and copy by e-service to Shelly
Doggett, Esq., P. O. Box 12548, MC-066, Austin, Texas 78711-2548 in
accordance with the Texas Rules of Civil Procedure on the 22nd day of January
2015.
/s/ Larry Mark Polsky, Esq.
LARRY MARK POLSKY, ESQ.
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