Daniel Lorenzo Wilson v. State ( 2015 )

ACCEPTED
03-15-00328-cr
6722699
THIRD COURT OF APPEALS
AUSTIN, TEXAS
8/31/2015 12:23:26 PM
JEFFREY D. KYLE
CLERK
No. 03-15-00328-CR
DANIEL LORENZO WILSON § IN THE THIRDFILED IN
3rd COURT OF APPEALS
§ AUSTIN, TEXAS
v. § COURT OF8/31/2015
APPEALS 12:23:26 PM
§ JEFFREY D. KYLE
Clerk
THE STATE OF TEXAS § AUSTIN, TEXAS
APPELLANT’S MOTION
FOR LEAVE TO AMEND BRIEF
Appellant Daniel Wilson asks this Court to permit him to amend the
Appellant’s Brief previously filed in this cause.
A. INTRODUCTION
1. Appellant is Daniel Lorenzo Wilson; appellee is the State of Texas.
2. The Appellant’s Brief was filed August 24, 2015.
3. On page 23 of the brief, Appellant inadvertently identified “State’s
Exhibits 4, 7, 8 and 15-18” as the exhibits that he was challenging on
appeal. However, every other reference to the challenged exhibits makes
clear that the appellate complaint challenges the admission of State’s
Exhibits 9, 13, 14, 25, 31, 34 and 35. See Appellant’s Brief at 24-25.
B. ARGUMENT & AUTHORITIES
4. “A brief may be amended or supplemented whenever justice
requires, on whatever reasonable terms the court may prescribe.” TEX. R.
APP. P. 38.7.
5. Appellant requests leave to amend the Appellant’s Brief by correcting
the exhibit numbers referenced on page 23 of the brief to correspond to
the seven exhibits plainly challenged on the subsequent two pages of the
brief.
6. Appellant is furnishing an amended brief contemporaneously with
this Motion.
Motion to Amend Brief Page 1
C. PRAYER
7. For these reasons, Appellant Daniel Lorenzo Wilson asks the Court to
grant this motion and permit him to amend his brief as requested.
Respectfully submitted,
/s/ Alan Bennett
E. Alan Bennett
Counsel for Appellant
SBOT #02140700
Sheehy, Lovelace & Mayfield, P.C.
510 N. Valley Mills Dr., Ste. 500
Waco, TX 76710
Telephone: (254) 772-8022
Fax: (254) 772-9297
Email: abennett@slmpc.com
Certificate of Service
The undersigned hereby certifies that a true and correct copy of this
document has been served on August 31, 2015 to counsel for the State, Bob
Odom, bob.odom@co.bell.tx.us, by e-service.
/s/ Alan Bennett
E. Alan Bennett
Motion to Amend Brief Page 2