Perry, Ex Parte James Richard "Rick"

Opinion

PD-1067-15

FILED IN COURT OF CRIMINAL APPEALS COURT OF CRIMINALAPPEALS AUSTIN, TEXAS Transmitted 11/23/2015 3:54:41 PM N. Q . Qr Oo oni(- Accepted 11/23/2015 4:04:21 PM November 23,2015 K ARP, arnqT, ABEL ACOSTA

NO. PD-1067-15 CLERK

ABEL ACOSTA, CLERK IN THE /frv>^*& "

COURT OF CRIMINAL APPEALS OF TEXAS Q ,£,,

EX PARTE JAMES RICHARD "RICK" PERRY, I\ " 21 "^ Appellant

On Appeal from the 390th Judicial District Court, Travis County, Texas, Cause No. D-l-DC-14 100139

APPELLANT'S MOTION FOR LEAVE TO FILE POST-ORAL ARGUMENT SUBMISSION IN CONNECTION WITH HIS BRIEF ON THE MERITS ADDRESSING HIS PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE JUDGES OF SAID COURT:

COMES NOW Appellant, James Richard "Rick" Perry (Governor Perry), and

pursuant to Tex.R. App.P. 71.4, seeks leave of Court to file a brief, post-oral

argument submission.

As the Court is aware, oral argument was presented on November 18, 2015.

Governor Perry desires to file a brief, post-oral argument submission in order to

provide cases which were discussed, but not specifically identified during the oral

argument. Furthermore, precise page references to all of the State's judicial

admissions appear to be necessary and appropriate.

WHEREFORE, PREMISES CONSIDERED, Governor Perry prays that this

Court grant this motion and allow the filing of his post-oral argument submission.

Respectfully submitted,

BOTSFORD & ROARK /s/David L. Botsford David L. Botsford State Bar No. 02687950 1307 West Ave. Austin, Texas 78701 dbotsford@aol.com Telephone: 512-479-8030 Facsimile: 512-479-8040

THE BUZBEE LAW FIRM /s/ Anthony G. Buzbee Anthony G. Buzbee State Bar No. 24001820 JPMorgan Chase Tower 600 Travis Street, Suite 7300 Houston, Texas 77002 Tbuzbee@txattorneys.com Telephone: 713-223-5393 Facsimile: 713-223-5909

BAKER BOTTS L.L.P. /s/ Thomas R. Phillips Thomas R. Phillips State Bar No. 00000102 98 San Jacinto Blvd., Suite 1500 Austin, Texas 78701-4078 tom.phillips@bakerbotts.com Telephone: 512-322-2565 Facsimile: 512-322-8363

Certificate of Service

I hereby certify that a true and correct copy of the above and foregoing has been delivered to all counsel at the time it was electronically filed.

BOTSFORD & ROARK /s/ David L. Botsford