Simpson, Mark Twain ( 2015 )

PD-0599-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
December 11, 2015 Transmitted 12/10/2015 3:48:48 PM
Accepted 12/11/2015 8:51:48 AM
ABEL ACOSTA
PD-0599-15 CLERK
MARK TWAIN SIMPSON § IN THE TEXAS
§
v. § COURT OF
§
THE STATE OF TEXAS § CRIMINAL APPEALS
PETITIONER’S MOTION FOR LEAVE
OF COURT TO FILE REPLY BRIEF
TO THE HONORABLE JUDGES OF SAID COURT:
NOW COMES Petitioner-Appellee Mark Twain Simpson, and
submits this motion for leave of court to file a reply brief. In support
thereof, Simpson would show the following:
I.
Simpson filed a brief in the above-listed matter in this Court on
November 9, 2015. On December 9, 2015, the State filed its response.
II.
The State’s brief does not address the issue raised in Simpson
brief. Instead, the State again attempts to re-litigate the issue already
properly decided by the trial court. Simpson’s reply brief both clarifies
this for this Court and explains why the State’s failure to address the
issue raised in Simpson’s brief reveals its merit.
Accordingly, Appellant prays that this motion for leave of court to
file reply brief be granted.
Respectfully submitted,
/s/ Bruce Anton
BRUCE ANTON
Bar Card No. 01274700
ba@sualaw.com
/s/ Brett Ordiway
BRETT ORDIWAY
Bar Card No. 24079086
bordiway@sualaw.com
SORRELS, UDASHEN & ANTON
2311 Cedar Springs Road
Suite 250
Dallas, Texas 75201
(214)-468-8100 (office)
(214)-468-8104 (fax)
Attorneys for Petitioner-Appellee
Certificate of Service
I, the undersigned, hereby certify that a true and correct copy of
the foregoing Appellant’s Motion for Leave of Court to File Reply Brief
was electronically served to the Dallas County District Attorney’s Office
and the State Prosecuting Attorney on December 10, 2015.
/s/ Bruce Anton
BRUCE ANTON
Bar Card No. 01274700
ba@sualaw.com