PD-0122-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 8/25/2015 10:25:01 AM
Accepted 8/25/2015 10:28:31 AM
IN THE COURT OF CRIMINAL APPEALS ABELAC°erk
OF TEXAS
FILED IN
COURT OF CRIMINAL APPEALS
ERIC DWAYNE STEVENSON,
August 25, 2015
APPELLANT
R ABELACOSTA, CLERK
V. § NO. PD-0122-15
THE STATE OF TEXAS, §
APPELLEE §
STATE'S MOTION FOR LEAVE TO FILE A POST-SUBMISSION
SUPPLEMENTAL BRIEF
TO THE HONORABLE COURT OF CRIMINAL APPEALS:
COMES NOW, the State of Texas, pursuant to Texas Rule of
Appellate Procedure 70.4, and files this motion for leave to file a
post-submission supplemental brief. In support of its motion, the State
would show the Court the following:
Both parties have filed their briefs and this cause was submitted on
August 5, 2015.
II.
The State requests leave to file a supplemental brief in order to apprise
the Court of recent changes by the Texas Legislature to the statutory
language for criminally prosecuting sexually violent predators for violating
their civil commitment requirements which impact the appellant's
convictions. See 2015 Tex. Sess. Law Serv. Ch. 845 (S.B. 746) §13 (to be
codified at Tex. Health & Safety Code Ann. § 841.082(a)) & 2015 Tex. Sess.
Law Serv. Ch, 845 (S.B. 746) §19 (to be codified at Tex. Health & Safety
Code Ann. §841.085(a)).
WHEREFORE, PREMISES CONSIDERED, the State prays that the
Court grant this motion for leave to file the State's post-submission
supplemental brief and that the Court file the State's post-submission
supplemental brief.
Respectfully submitted,
SHAREN WILSON
Criminal District Attorney
Tarrant County, Texas
DEBRA WINDSOR
Chief, Post-Conviction
/s/ Steven W. Conder
Criminal District Attorney
401 W. Belknap
Fort Worth, Texas 76196-0201
(817)884-1687
FAX (817) 884-1672
State Bar No. 04656510
COAAppellatealerts@tarrantcountvtx.qov
CERTIFICATE OF SERVICE
True copies of the State's post-submission supplemental brief have
been electronically served on opposing counsel, the Hon. Scott Walker
(scott(5)lawverwalker.com), 222 W. Exchange Avenue, Fort Worth, Texas
76164; and the State Prosecuting Attorney, the Hon. Lisa McMinn
(information@spa.texas.gov), P.O. Box 13046, Austin, Texas 78711-3046,
on this, the 25th day of August, 2015.
/s/ Steven W. Conder
STEVEN W. CONDER
d 8.Stevenson eric dwayne.mi/leave to supplement