PD-1067-1
COURT OF CRIMINAL APPEAL
AUSTIN, TEXA
Transmitted 11/12/2015 4:35:24 PI
Accepted 11/13/2015 8:04:41 Af
ABEL ACOST,
No. PD-1067-15 CLER
TO THE COURT OF CRIMINAL APPEALS
FILED IN
COURT OF CRIMINALAPPEALS
OF THE STATE OF TEXAS
November 13, 2015
ABELACOSTA, CLERK
Ex parte James Richard "Rick" Perry
Appeal from Travis County
MOTION FOR LEAVE TO FILE
STATE'S RESPONSE TO APPELLANT'S BRIEF ON THE MERITS
ADDRESSING THE STATE'S PETITION FOR DISCRETIONARY REVIEW
* *
LISA C. McMINN
State Prosecuting Attorney
Barl.D. No. 13803300
P.O. Box 13046
Austin, Texas 78711
information@spa.texas.gov
512/463-1660 (Telephone)
512/463-5724 (Fax)
TO THE HONORABLE COURT OF CRIMINAL APPEALS:
On October 7, 2015, this Court granted Appellant's and the State's Petitions
for Discretionary Review and expedited briefing and oral argument. Oral argument
is scheduled for November 18, 2015.
The State's Response, filed contemporaneously with this motion, addresses
some of the arguments raised in Appellant's Brief. This case presents complex
constitutional issues, and the State believes its response will clarify the issues for oral
argument and aid the Court in its decision.
WHEREFORE, the State of Texas prays that this Court grant its motion for
leave to file State's Response to Appellant's Brief on the Merits Addressing the
State's Petition for Discretionary Review.
Respectfully submitted,
/s/ LISA C. McMINN
LISA C. McMINN
State Prosecuting Attorney
Barl.D. No. 13803300
P.O. Box 13046
Austin, Texas 78711
information@spa.texas.gov
512/463-1660 (Telephone)
512/463-5724 (Fax)
CERTIFICATE OF SERVICE
The undersigned certifies that on this 12th day of November, 2015, the State's
Motion for Leave to File Response to Appellant's Briefon the Merits Addressing the
State's Petition for Discretionary Review was served via certified electronic service
provider to:
Anthony G. Buzbee
Tbuzbee@txattomeys.com
David L. Botsford
dbotsford@aol.com
Thomas R. Phillips
tom.phillips@bakerbotts.com
Michael McCrum
michael@McCrumlaw.com
David Gonzalez
david@sg-llp.com
Isi LISA C. McMINN
LISA C. McMINN
State Prosecuting Attorney