Ambrose, Cynthia
Opinion
FILED IN PD-0143-15 ror^MAi APPEALS COURT OF CRIMINAL addpa, c COURT OF CRIMINAL AUST|NAPPEALS
JEXAS
October 16 2015 Transmitted 10/16/2015 2:28:54 PM Accepted 10/16/2015 2:59:31 PM ABEL ACOSTA, CLERK PD-0143-15 ABEL A£°|rK IN THE COURT OF CRIMINAL APPEALS ^ OF THE STATE OF TEXAS
THE STATE OF TEXAS, Appellant
v.
CYNTHIA AMBROSE, Appellee
Appeal from Bexar County
MOTION FOR LEAVE TO FILE
STATE PROSECUTING ATTORNEY'S POST-SUBMISSION BRIEF
AS AMICUS CURIAE
*****
LISA C. McMINN
State Prosecuting Attorney BarI.D.No.13803300
JOHN R. MES SINGER
Assistant State Prosecuting Attorney Bar I.D. No. 24053705
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:
The State Prosecuting Attorney respectfully presents her motion for leave to
file a Post-Submission Brief as Amicus Curiae under Texas Rule of Appellate
Procedure 71.4. The State believes that re-examination of this Court's cases on the
standard for review of unpreserved charge error will assist the Court in resolving
Appellee's issues presented.
PRAYER FOR RELIEF
WHEREFORE, the State of Texas prays that the Court of Criminal Appeals
grant it leave to file its Post-Submission Brief as Amicus Curiae.
Respectfully submitted,
/s/ John R. Messinger JOHN R. MESSINGER Assistant State Prosecuting Attorney Bar I.D. No. 24053705
P.O. Box 13046 Austin, Texas 78711 information@spa.texas.gov 512/463-1660 (Telephone) 512/463-5724 (Fax)
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this 16th day of October, 2015, a
true and correct copy of the State's Motion for Leave to File a Post-Submission
Brief as Amicus Curiae has been eFiled or e-mailed to the following:
Dayna L. Jones 1800 McCullough Avenue San Antonio, Texas 78212 davnaj33@gmail.com
S. Patrick Ballantyne Assistant Criminal District Attorney 101 W.Nueva St., 7th floor San Antonio, Texas 78205 sballantyne@bexar.org
Isi John R. Messinger John R. Messinger Assistant State Prosecuting Attorney
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