COMES NOW, the State of Texas, pursuant to Texas Rule of Appellate Procedure 70.4, and files this motion for leave to file a post-submission supplemental brief. In support of its motion, the State would show the Court the following:

Both parties have filed their briefs and this cause was submitted on August 5, 2015.

II. The State requests leave to file a supplemental brief in order to apprise *2 the Court of recent changes by the Texas Legislature to the statutory language for criminally prosecuting sexually violent predators for violating their civil commitment requirements which impact the appellant's convictions. See 2015 Tex. Sess. Law Serv. Ch. 845 (S.B. 746) §13 (to be codified at Tex. Health & Safety Code Ann. § 841.082(a)) & 2015 Tex. Sess.

Law Serv. Ch, 845 (S.B. 746) §19 (to be codified at Tex. Health & Safety Code Ann. §841.085(a)).

WHEREFORE, PREMISES CONSIDERED, the State prays that the Court grant this motion for leave to file the State's post-submission supplemental brief and that the Court file the State's post-submission supplemental brief.

Respectfully submitted, SHAREN WILSON Criminal District Attorney Tarrant County, Texas DEBRA WINDSOR Chief, Post-Conviction Criminal District Attorney 401 W. Belknap Fort Worth, Texas 76196-0201 (817)884-1687 FAX (817) 884-1672 *3 State Bar No. 04656510 COAAppellatealerts@tarrantcountvtx.qov CERTIFICATE OF SERVICE True copies of the State's post-submission supplemental brief have been electronically served on opposing counsel, the Hon. Scott Walker (scott(5)lawverwalker.com), 222 W. Exchange Avenue, Fort Worth, Texas 76164; and the State Prosecuting Attorney, the Hon. Lisa McMinn (information@spa.texas.gov), P.O. Box 13046, Austin, Texas 78711-3046, on this, the 25th day of August, 2015.

STEVEN W. CONDER

d 8.Stevenson eric dwayne.mi/leave to supplement