Thomas, Kenneth Dewayne

Opinion

AP-77,047

COURT OF CRIMINAL APPEALS AUSTIN, TEXAS

Transmitted 6/19/2015 3:11:10 PM JOHN TATUM 990 S. Sherman ATTORNEY AT LAW Accepted 6/19/2015 3:24:57 PM Richardson, Texas 75081 (972) 705-9200 ABEL ACOSTA CLERK

June 19, 2015

Court of Criminal Appeals June 22, 2015

c/o Abel Acosta Chief Deputy Clerk P.O. Box 12308 Capitol Station Austin, Texas 78711

Re: Oral argument in Cause No. AP-77,047 Kenneth Thomas v. The State of Texas

Dear Mr. Acosta:

Pursuant to Rule 71.3 Texas Rules of Appellate Procedure, I am advising this Honorable Court that I, on behalf of Appellant in the above referenced cause, am requesting oral argument on issues Nos. 31- 34, 47-48 and 50. T hese issues concern voir dire on intellectual disability, whether Briseno factors are constitutional, sufficiency of evidence of intellectual disability and whether the jury was properly charged on intellectual disability.

I believe oral argument would help present these issues in full context and help present a comparative analysis of the issues raised. Therefore, I respectfully request oral argument on these issues.

Sincerely,

/s/ John Tatum John Tatum

JT:mt