Larry Mark Polsky v. State

Opinion

ACCEPTED

03-14-00068-CV

3865786

THIRD COURT OF APPEALS

AUSTIN, TEXAS

1/22/2015 3:13:29 PM

JEFFREY D. KYLE

CLERK

APPEAL NO. 03-14-00068-CV

FILED IN

3rd COURT OF APPEALS

AUSTIN, TEXAS

COURT OF APPEALS FOR THE THIRD DISTRICT1/22/2015 OF TEXAS3:13:29 PM JEFFREY D. KYLE

AUSTIN, TEXAS Clerk

LARRY MARK POLSKY, APPELLANT VS.

THE STATE OF TEXAS, APPELLEE

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APPEAL FROM CAUSE NO. D-1-GV-13-000067 IN THE 126TH DISTRICT COURT OF TRAVIS COUNTY, TEXAS

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APPELLANT’S MOTION FOR PERMISSION TO FILE ADDITIONAL

AUTHORITY

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TO THE HONORABLE THIRD COURT OF APPEALS:

COMES NOW, Appellant, Larry Mark Polsky, Esq., and hereby requests

this Honorable Court for leave to file additional authority and would show as

follows:

1. Attached as Exhibit “A” are the applicable pages are the current Cameron

County Beach Access and Dune Protection Plan.

2. That the main thrust of Polsky’s appeal is that Javier Mendez who is the

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Parks and Recreation Director of Cameron County was the sole

individual who would report “alleged” violations of Polsky’s dune

protection permit to the Cameron County Commissioners.

3. That the attached “authority” supports Polsky’s position as to this portion

of his argument.

WHEREFORE, Larry Mark Polsky, Esq. respectfully requests this

Honorable Court to allow him to file the attached additional authority which was

previously filed as “Notice of Additional Authority.”

Please govern yourselves accordingly.

/s/ Larry Mark Polsky, Esq. LARRY MARK POLSKY, ESQ. State Bar No. 16105500 Law Office of Larry Mark Polsky 5508 Padre Blvd. South Padre Island, Texas 78597 (956) 761-1529 Telephone (956) 761-1599 Facsimile

CERTIFICATE OF CONFERENCE

I certify that I have previously emailed Shelly Doggett, Esq. and informed

her that I would be filing the above “Notice of Additional Authority.” Ms. Doggett

has not emailed me back to date stating whether or not she objects to same.

/s/ Larry Mark Polsky, Esq. LARRY MARK POLSKY, ESQ.

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CERTIFICATE OF SERVICE

I certify that the original of this document was served on the Third Court of

Appeals in Austin, Texas for filing by e-filing and copy by e-service to Shelly

Doggett, Esq., P. O. Box 12548, MC-066, Austin, Texas 78711-2548 in

accordance with the Texas Rules of Civil Procedure on the 22nd day of January

2015.

/s/ Larry Mark Polsky, Esq. LARRY MARK POLSKY, ESQ.