Adan Flores v. State

Opinion

ACCEPTED 04-14-00915-cr

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

8/31/2015 4:49:53 PM

KEITH HOTTLE

CLERK

IN THE FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS

FILED IN

4th COURT OF APPEALS SAN ANTONIO, TEXAS

Adan Flores v. The State of Texas 08/31/2015 4:49:53 PM KEITH E. HOTTLE

Clerk

NO. 04-14-00915-CR

Trial Court No. 2014CRS000311-D1

STATE’S MOTION FOR LEAVE TO FILE ADDITIONAL CITATIONS

TO THE HONORABLE JUSTICES OF SAID COURT:

NOW COMES THE STATE OF TEXAS, and respectfully moves the Court

to permit the filing of the attached additional citations and commentary in support

of the State’s Brief. Although Local Rule 8.3 permits the filing of additional

citations and succinct commentary without leave of the Court, and the attached

document consists only of citations and commentary, it totals 25 pages and 5,449

words due to the sheer number of cases summarized: there are fifteen fully

summarized cases (for and against the State’s position), two tables of further

citations, and about a page and a half of summarizing commentary. Therefore, out

of an abundance of caution, the State requests leave to file the attached document

as if it was a supplemental brief under Local Rule 8.4.

STATE’S ADDITIONAL CITATIONS PAGE 1 OF 3

PRAYER

WHEREFORE, PREMISES CONSIDERED, the State prays the Court grant

leave to file the attached document.

Respectfully submitted,

ISIDRO R. ALANIZ DISTRICT ATTORNEY 49TH JUDICIAL DISTRICT

By:___/s/__________________ David L. Reuthinger, Jr. Assistant District Attorney Webb County, 49th Judicial District 1110 Victoria St., Suite 401 Laredo, Texas 78040 (956) 523-4900 / (956) 523-5070 (Fax) Bar No. 24053936 ATTORNEY FOR APPELLEE

STATE’S ADDITIONAL CITATIONS PAGE 2 OF 3

CERTIFICATE OF COMPLIANCE

The word count of the foregoing document is 148.

Date: August 31, 2015

___/s/__________________ David L. Reuthinger, Jr. Attorney for Appellee

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and foregoing document has been delivered to Armando Trevino, attorney for the Appellant, via eFileTexas e-Service to Armando_trevinolaw@hotmail.com

Date: August 31, 2015.

___/s/__________________ David L. Reuthinger, Jr. Attorney for Appellee

STATE’S ADDITIONAL CITATIONS PAGE 3 OF 3