Cameron, Vanessa

Opinion

PD-1427-13

COURT OF CRIMINAL APPEALS AUSTIN, TEXAS

Transmitted 3/11/2015 7:22:07 PM March 12, 2015 Accepted 3/12/2015 8:56:36 AM ABEL ACOSTA

No. PD-1427-13 CLERK

IN THE TEXAS COURT OF CRIMINAL APPEALS

VANESSA CAMERON, Petitioner,

v.

STATE OF TEXAS, Respondent.

MOTION FOR LEAVE TO FILE REPONSE TO STATE’S REPLY

TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS, SAN ANTONIO, TEXAS:

NOW COMES, Petitioner, VANESSA CAMERON, by and through

undersigned counsel files this motion for leave to file a Reply to the State’s Brief

and in support of same would show the following:

1. On February 13, 2015 this Honorable Court notified Counsel that the Court

would allow oral argument and further briefing on rehearing, for

submission on March 18, 2015.

2. The State filed its Brief Following the Granting of Rehearing on Petition

for Discretionary Review on February 20, 2015.

3. Undersigned counsel are filing their Reply Brief promptly to give this

Honorable Court time to sufficiently review this Brief prior to submission.

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WHEREFORE, PREMISES CONSIDERED, the Petitioner, Vanessa

Cameron, respectfully prays that this Honorable Court grant this Motion for Leave

to File a Reply to State’s Brief.

Respectfully submitted:

GERALD H. GOLDSTEIN Bar No. 08101000 DONALD H. FLANARY Bar No. 24045877 GOLDSTEIN, GOLDSTEIN AND HILLEY 310 S. St. Mary’s St. 29th Floor Tower Life Bldg. San Antonio, Texas 78205 210-226-1463 210-226-8367 facsimile

JOHN T. HUNTER Bar No. 24077532 310 S. St. Mary’s St. Suite 1840- Tower Life Bldg. San Antonio, Texas 78205 210-399-8669 210-568-4927 facsimile

By: /s/ Gerald H. Goldstein Gerald H. Goldstein

Attorneys for Applicant, VANESSA CAMERON

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CERTIFICATE OF SERVICE

This is to certify that on March 11, 2015, a true and correct copy of the above and

foregoing document was served on Jay Brandon, Assistant District Attorney at the Bexar

County District Attorney’s Office, by electronic mail to jay.brandon@bexar.org.

By: /s/ Gerald H. Goldstein Gerald H. Goldstein