FILED IN
COURT OF CRIMINAL APPEALS
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PD1396-1·
COURT OF CRIMINAL APPEAL
AUSTIN, TEXA
April 23, 2015
ABELACOSTA,CLERK
C ause 1:
Utl~W.L-- Transmitted 4/22/2015 4:53:14 PI
D -1396 - 14 n 0
h 7 }41) . -
IN THE TEXAS COURT OF CRIMINAL APPEALS
Accepted 4/23/2015 7:41:22 AI
ABEL ACOST,
CLER
JON THOMAS FORD, § FROM THE FOURTH COURT OF
Petitioner, § APPEALS, SAN ANTONIO, TEXAS
§No. 04-12-00317-CR
vs. §
§ [On Appeal from Cause No.
THE STATE OF TEXAS, § 201 O-CR-77 41 in the 186th Dist. Court,
Respondent. §Bexar County, San Antonio, Texas]
PETITIONER'S UNOPPOSED MOTION FOR LEAVE TO FILE
AMENDED BRIEF ON PETITION FOR DISCRETIONARY REVIEW
. TO THE HONORABLE JUDGES OF SAID COURT:
NOW COMES Petitioner, JON THOMAS FORD, by and through his
undersigned counsel and pursuant to Rule 38.7 of the Texas Rules of Appellate
Procedure files this unopposed motion for leave to file his Amended Brief on
Petition for Discretionary Review, attached here, to withdraw Ground three from
the original brief filed. In support of same, the Petitioner will show as follows:
1. Undersigned counsel has conferred with Assistant District Attorney Jay
Brandon and he does not oppose this motion.
2. Undersigned counsel neglected to carefully read the postcard granting
grounds on Petition for Discretionary Review and believed that the Court
granted Grounds one, two and three, based on her oversight and quick
cursory reading of the postcard.
3. After reading the State's brief that Ground three was not granted,
undersigned counsel re-read the postcard granting Petition for Discretionary
Review and acknowledges that the postcard granted Grounds one and two
only.
4. Therefore, undersigned counsel apologizes to this Court and to Assistant
District Attorney Jay Brandon for any inconvenience this may have caused.
5. Undersigned counsel requests leave to file an amended brief withdrawing
Ground three and it's briefing, consisting of two and one-half pages and a
one paragraph summary of the argument.
6. The amended brief, removing only those matters, is attached to this motion
for leave for filing and for the convenience of the Court.
WHEREFORE PREMISES CONSIDERED, Petitioner respectfully prays
that this Honorable Court grant this unopposed motion and file his Amended Brief
on Petition for Discretionary Review.
Respectfully Submitted:
_ _Is/Cynthia E. Orr_ _ _ _ __
Cynthia E. Orr
Bar No. 15313350
GOLDSTEIN, GOLDSTEIN & HILLEY
2
310 S. St. Mary's St.
29th Floor Tower Life Bldg.
San Antonio, Texas 78205
210-226-1463
210-226-8367 facsimile
whi teco llarlaw@gmail. com
Attorney for Petitioner,
JON THOMAS FORD
CERTIFICATE OF CONFERENCE
This is to certify that undersigned counsel has conferred with Assistant
District Attorney Jay Brandon and he does not oppose this motion.
_ _Is/Cynthia E. Orr_ _ _ _ __
Cynthia E. Orr
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the above Unopposed Motion has been
sent via E-file.Texas.gov, as registered participants, on this the 22nd day of April,
.2015 to the following:
Nicolas LaHood
District Attorney
Jay Brandon
Assistant District Attorney
Paul Elizondo Tower
101 West Nueva, Fo~rth Floor
San Antonio, Texas 78205
E-mail: jay.brandon@bexar.org,
_ _Is/Cynthia£. Orr_ _ _ _ __
Cynthia E. Orr
3
Ford, Jon Thomas
Combined Opinion