Ford, Jon Thomas ( 2015 )

FILED IN C^T-7 f jt PD1396-14
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7 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
April 29, 2015 <±"' "a* C&^sjQ Transmitted 4/29/2015 2:53:40 PM
r . Accepted 4/29/2015 3:01:56 PM
abelacosta, clerk Cause No. PD-1396-14 7/2* /2a (^ ABEL A£°f™
IN THE TEXAS COURT OF CRIMINAL APPEALS
JON THOMAS FORD, § FROM THE FOURTH COURT OF
Petitioner/Appellant, § APPEALS, SAN ANTONIO, TEXAS
§ No. 04-12-00317-CR
vs. §
§ [On Appeal from Cause No.
THE STATE OF TEXAS, § 2010-CR-7741 in the 186th Dist. Court,
Respondent/Appellee. § Bexar County, San Antonio, Texas]
PETITIONER'S UNOPPOSED MOTION FOR LEAVE TO FILE
REPLY TO APPELLEE'S BRIEF ON THE MERITS
AFTER GRANTING OF DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF SAID COURT:
NOW COMES Petitioner, JON THOMAS FORD, by and through his
undersigned counsel and pursuant to Rules 38.3 and 70.4 of the Texas Rules of
Appellate Procedure files this unopposed motion for leave to file his Reply to
Appellee's Brief on the Merits After Granting of Discretionary Review. In support
of same, the Petitioner will show as follows:
1. Undersigned counsel has conferred with Assistant District Attorney Jay
Brandon and he does not oppose this motion.
2. Rule 38.3 permits Appellant to file a reply brief so he may respond to
Appellee's brief.
WHEREFORE PREMISES CONSIDERED, Petitioner respectfully prays
that this Honorable Court grant this unopposed motion and file his Reply to
Appellee's Brief on the Merits After Granting of Discretionary Review.
Respectfully Submitted:
/s/Cynthia E. Orr
Cynthia E. Orr
Bar No. 15313350
GOLDSTEIN, GOLDSTEIN & HILLEY
310 S. St. Mary's St.
29th Floor Tower Life Bldg.
San Antonio, Texas 78205
210-226-1463
210-226-8367 facsimile
whitecollarlaw@gmail.com
Attorney for Petitioner,
JON THOMAS FORD
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the above Motion has been sent via E-
file.Texas.gov, as registered participants, on this the 29th day of April, 2015 to the
following:
Nicolas LaHood
District Attorney
Jay Brandon
Assistant District Attorney
Paul Elizondo Tower
101 West Nueva, Fourth Floor
San Antonio, Texas 78205
E-mail: jay.brandon@bexar.org,
Js/Cynthia E. Orr
Cynthia E. Orr