Case Information

*1 PD-1427-13 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 3/11/2015 7:22:07 PM Accepted 3/12/2015 8:56:36 AM ABEL ACOSTA No. PD-1427-13 CLERK IN THE TEXAS COURT OF CRIMINAL APPEALS

VANESSA CAMERON,

Petitioner,

v.

STATE OF TEXAS,

Respondent. MOTION FOR LEAVE TO FILE REPONSE TO STATE’S REPLY TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS, SAN ANTONIO, TEXAS:

NOW COMES, Petitioner, VANESSA CAMERON, by and through undersigned counsel files this motion for leave to file a Reply to the State’s Brief and in support of same would show the following:

1. On February 13, 2015 this Honorable Court notified Counsel that the Court

would allow oral argument and further briefing on rehearing, for submission on March 18, 2015.

2. The State filed its Brief Following the Granting of Rehearing on Petition

for Discretionary Review on February 20, 2015. 3. Undersigned counsel are filing their Reply Brief promptly to give this

Honorable Court time to sufficiently review this Brief prior to submission. *2 WHEREFORE, PREMISES CONSIDERED, the Petitioner, Vanessa Cameron, respectfully prays that this Honorable Court grant this Motion for Leave to File a Reply to State’s Brief.

Respectfully submitted:

GERALD H. GOLDSTEIN

Bar No. 08101000

DONALD H. FLANARY

Bar No. 24045877

GOLDSTEIN, GOLDSTEIN AND HILLEY 310 S. St. Mary’s St.

29 th Floor Tower Life Bldg.

San Antonio, Texas 78205

210-226-1463

210-226-8367 facsimile JOHN T. HUNTER

Bar No. 24077532

310 S. St. Mary’s St.

Suite 1840- Tower Life Bldg.

San Antonio, Texas 78205

210-399-8669

210-568-4927 facsimile

Gerald H. Goldstein

Attorneys for Applicant,

VANESSA CAMERON

CERTIFICATE OF SERVICE This is to certify that on March 11, 2015, a true and correct copy of the above and foregoing document was served on Jay Brandon, Assistant District Attorney at the Bexar County District Attorney’s Office, by electronic mail to jay.brandon@bexar.org.

Gerald H. Goldstein