Harris, Roderick

IN THE COURT OF CRIMINAL APPEALS AUSTIN, TEXAS RECEIVED COURT OF CRIMINAL APPEALS 4/21/2015 ) Cause No. ABEL ACOSTA, CLERK In re ) w0e-0040e-Y(A) Roderick Harris, ) RELATOR ) ) ) MOTION FOR LEAVE TO FILE EMERGENCY APPLICATION FOR WRIT OF PROHIBITION This is a Capital Case BRAD D. LEVENSON (No. 2407341r) Director, Office of Capital Writs (E-Mail : Brad.Levenson@ocw.texas. gov) ROBERT ROMIG (No. 24060s 17) (E-Mail: Robert.Romig@ocw.texas.gov) JEREMY SCHEPERS (No. 24084578) (E-Mail : Jeremy.Schepers@ocw.texas.gov) Post-Conviction Attorneys Office of Capital Writs 1700 N. Congress Ave, Suite 460 Austin, Texas 787II (s12) 463-8600 (s12) 463-8se0 (fa") Attorneys for Relator IN THE COURT OF CRIMINAL APPEALS AUSTIN, TEXAS ) Cause No. In re ) \ry09-oo4o9-Y(A) Roderick Harris, ) RELATOR ) ) ) MOTION FOR LEAVE TO FILE EMERGENCY APPLICATION FOR WRIT OF PROHIBITION Roderick Harris, by and through his counsel the Office of Capital Writs ("OCW"), pursuant to Texas Rule of Appellate Procedure 72.1, files this Motion for Leave to File an Emergency Application for Writ of Prohibition. PRAYER FOR RELIEF For the reasons expressed in the Emergency Application for Writ of Prohibition, Harris respectfully requests this Court grant Harris leave to file the Emergency Application and grant the relief therein requested. Respectfully submitted, DATED: April 2I,2015 ú BRAD D. LEVENSON Director, Office of Capital Writs 1 CERTIFICATE OF SERVICE I, the undersigned, declare and certify that I have served the foregoing Motion to Court of Criminal Appeals Honorab I e Judge Elizab eth Frizel I P.O. Box 112308 Criminal District Court No. 7 Austin, Texas 78711 133 N. Riverfront Blvd. Lock Box 54 Dallas, Texas 75207 Dallas County District Attorney cio Shelly Yeatts 133 N. Riverfront Blvd. Lock Box 19 Dallas, Texas 75207 Roderick Harris TDCJ # 99957 7 TDCJ Polunsky Unit 3872 FM 350 South Livingston, Texas 7735I This certification is executed on Apri|2l,2015, at Austin, Texas. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. -.-J BRAD D. LEVENSO