ACCEPTED
12-15-00154-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
10/23/2015 3:35:07 PM
Pam Estes
CLERK
NUMBER 12-15-00154-CR
DANIEL LEE KNOD § IN THE COURT OF APPEALS
FILED IN
12th COURT OF APPEALS
§ TYLER, TEXAS
v. § 12TH JUDICIAL DISTRICT
10/23/2015 3:35:07 PM
§ PAM ESTES
Clerk
THE STATE OF TEXAS § TYLER, TEXAS
STATE’S MOTION FOR LEAVE TO FILE
SUPPLEMENTAL BRIEF
TO THE HONORABLE COURT OF APPEALS:
Comes now the State of Texas and presents this motion for leave to file a
supplemental brief in the above-captioned cause pursuant to Rule 38.7 of the
Texas Rules of Appellate Procedure. The State timely filed a response to
appellant’s original brief on 10 September 2015. On 22 September 2015,
appellant filed an amended brief raising a second issue not argued in his
original brief. The Court received a supplemental letter brief from the State
on 5 October 2015. As a brief may be supplemented whenever justice
requires or on whatever reasonable terms the court may prescribe, the State
respectfully requests the Court’s leave to file its supplemental brief and
respond to the newly alleged issue in the appellant’s amended brief. See Tex.
R. App. P. 38.7.
WHEREFORE, PREMISES CONSIDERED, the State of Texas prays that
this Court grant the foregoing motion and allow the filing of the State’s
Supplemental Letter Brief in the above-captioned cause1.
Respectfully submitted,
D. MATT BINGHAM
Criminal District Attorney
Smith County, Texas
/s/ Aaron S. Rediker
Aaron S. Rediker
Assistant District Attorney
SBOT #: 24046692
100 North Broadway, 4th Floor
Tyler, Texas 75702
Office: (903) 590-1720
Fax: (903) 590-1719 (fax)
arediker@smith-county.com
1
All facts recited in this motion not within the record or the Court’s knowledge in its
official capacity are within the personal knowledge of the undersigned attorney, and a
verification is therefore not required under Rule 10.2 of the Texas Rules of Appellate
Procedure.
2
CERTIFICATE OF COMPLIANCE
Pursuant to Texas Rule of Appellate Procedure 9.4(i)(3), the undersigned
attorney certifies that the word count for this document is 162 words as
calculated by Microsoft Word 2010.
/s/ Aaron S. Rediker
Aaron S. Rediker
CERTIFICATE OF SERVICE
On 23 October 2015, a true and complete copy of the foregoing motion
was sent by email to Austin R. Jackson, attorney for appellant, at
JLawAppeals@gmail.com.
/s/ Aaron S. Rediker
Aaron S. Rediker
3