PD-1427-13
F|LED|N COURT OF CRIMINAL APPEALS
COURT OF CRIMINALAPPEALS AUSTIN, TEXAS
Transmitted 3/11/2015 7:22:07 PM
March 12,2015 Accepted 3/12/2015 8:56:36 AM
xt~ im 1/10-7 11 ABELACOSTA
ABEL ACOSTA, CLERK JNO. rJJ-14Z/-lj, CLERK
J^y IN THE TEXAS COURT OF CRIMINAL APPEALS
0 \,r^ \6 VANESSA CAMERON,
^\ \ <^ Petitioner,
v.
STATE OF TEXAS,
Respondent.
MOTION FOR LEAVE TO FILE REPONSE TO STATE'S REPLY
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS,
SAN ANTONIO, TEXAS:
NOW COMES, Petitioner, VANESSA CAMERON, by and through
undersigned counsel files this motion for leave to file a Reply to the State's Brief
and in support of same would show the following:
1. On February 13,2015 this Honorable Court notified Counsel that the Court
would allow oral argument and further briefing on rehearing, for
submission on March 18, 2015.
2. The State filed its Brief Following the Granting of Rehearing on Petition
for Discretionary Review on February 20, 2015.
3. Undersigned counsel are filing their Reply Brief promptly to give this
Honorable Court time to sufficiently review this Brief prior to submission.
ELECTRONIC
RECORD
WHEREFORE, PREMISES CONSIDERED, the Petitioner, Vanessa
Cameron, respectfully prays that this Honorable Court grant this Motion for Leave
to File a Reply to State's Brief.
Respectfully submitted:
GERALD H. GOLDSTEIN
Bar No. 08101000
DONALD H. FLANARY
Bar No. 24045877
GOLDSTEIN, GOLDSTEIN AND HILLEY
310 S. St. Mary's St.
29th Floor Tower Life Bldg.
San Antonio, Texas 78205
210-226-1463
210-226-8367 facsimile
JOHN T. HUNTER
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: Is/ Gerald H. Goldstein
Gerald H. Goldstein
Attorneys for Applicant,
VANESSA CAMERON
CERTIFICATE OF SERVICE
This is to certify that on March 11, 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.
By: /s/ GeraldH. Goldstein
Gerald H. Goldstein