ACCEPTED
06-14-00079-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
6/3/2015 4:17:06 PM
DEBBIE AUTREY
CLERK
IN THE COURT OF APPEALS
SIXTH JUDICIAL DISTRICT OF TEXAS
AT TEXARKANA FILED IN
6th COURT OF APPEALS
TEXARKANA, TEXAS
JUSTIN SANDERS, 6/3/2015 4:17:06 PM
Appellant DEBBIE AUTREY
Clerk
vs. Appellate Cause No. 06-14-00079-CR
THE STATE OF TEXAS,
Appellee
APPELLANT'S MOTION FOR LEAVE
TO FILE SUPPLEMENTAL BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
COMES NOW the Appellant in the above styled and numbered cause and
respectfully moves the Court in accordance with Tex. R. App. Pro. Rule 38.7 for
leave to file Appellant’s Supplemental Brief and in support therefore would
respectfully show unto the Court as follows:
1. During oral argument Justice Moseley asked who bore the burden to
demonstrate attenuation of taint on a suppression issue and Justice Carter asked
how the court should proceed in determining if the search warrant was sufficient to
attenuate taint from a prior illegality.
2. Appellant has conducted additional research on those issues and believes the
filing of a short supplemental brief will aid the court in making a correct
determination of the issues.
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WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests this
Honorable Court grant leave to file Appellant’s Supplemental Brief in this cause.
Respectfully submitted,
CRAIG L. HENRY
Attorney at Law
723 Main Street
P.O. Box 3226
Texarkana, Texas 75504-3226
(903) 792-4645
FAX - (903) 792-5073
Lawyrntx@aol.com
By/s/ Craig L. Henry
Craig L. Henry
Arkansas Bar # 90142
Oklahoma Bar # 016779
Texas Bar # 09479260
Attorney for Appellant
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Motion has been delivered
electronically and via courier to Mr. Jerry Rochelle, Bowie County District Attorney, 601 Main
Street, Texarkana, Texas 75501, this 3rd day of June, 2015.
/s/ Craig L. Henry
Craig L. Henry
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Justin Sanders v. State
Combined Opinion