Case Information

*1 _ /7 fJ PD1396-1· "'H+f FILED IN COURT OF CRIMINAL APPEAL COURT OF CRIMINAL APPEALS 1: AUSTIN, TEXA Utl~W.L-- Transmitted 4/22/2015 4:53:14 PI April 23, 2015 Accepted 4/23/2015 7:41:22 AI D-1396 14 h 7 }41) . - ABEL ACOST, ABELACOSTA,CLERK C ause - n CLER IN THE TEXAS COURT OF CRIMINAL APPEALS JON THOMAS FORD, § FROM THE FOURTH COURT OF

Petitioner, § APPEALS, SAN ANTONIO, TEXAS §No. 04-12-00317-CR

vs. §

§ [On Appeal from Cause No. THE STATE OF TEXAS, § 201 O-CR -77 41 in the 186th Dist. Court,

Respondent. §Bexar County, San Antonio, Texas] PETITIONER'S UNOPPOSED MOTION FOR LEAVE TO FILE AMENDED BRIEF ON PETITION FOR DISCRETIONARY REVIEW . TO THE HONORABLE JUDGES OF SAID COURT:

NOW COMES Petitioner, JON THOMAS FORD, by and through his undersigned counsel and pursuant to Rule 38.7 of the Texas Rules of Appellate Procedure files this unopposed motion for leave to file his Amended Brief on Petition for Discretionary Review, attached here, to withdraw Ground three from the original brief filed. 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. Undersigned counsel neglected to carefully read the postcard granting

grounds on Petition for Discretionary Review and believed that the Court *2 granted Grounds one, two and three, based on her oversight and quick cursory reading of the postcard.

3. After reading the State's brief that Ground three was not granted,

undersigned counsel re-read the postcard granting Petition for Discretionary Review and acknowledges that the postcard granted Grounds one and two only.

4. Therefore, undersigned counsel apologizes to this Court and to Assistant

District Attorney Jay Brandon for any inconvenience this may have caused. 5. Undersigned counsel requests leave to file an amended brief withdrawing

Ground three and it's briefing, consisting of two and one-half pages and a one paragraph summary of the argument.

6. The amended brief, removing only those matters, is attached to this motion

for leave for filing and for the convenience of the Court.

WHEREFORE PREMISES CONSIDERED, Petitioner respectfully prays that this Honorable Court grant this unopposed motion and file his Amended Brief on Petition for Discretionary Review.

Respectfully Submitted: __ Is/Cynthia E. Orr __ __ _ _ Bar No. 15313350 GOLDSTEIN, GOLDSTEIN & HILLEY *3 310 S. St. Mary's St.

29th Floor Tower Life Bldg. San Antonio, Texas 78205 210-226-1463 210-226-8367 facsimile whi teco llarla w@gmail. com Attorney for Petitioner, JON THOMAS FORD CERTIFICATE OF CONFERENCE This is to certify that undersigned counsel has conferred with Assistant District Attorney Jay Brandon and he does not oppose this motion.

__ Is/Cynthia E. Orr _____ _ Cynthia E. Orr CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the above Unopposed Motion has been sent via E-file.Texas.gov, as registered participants, on this the 22nd day of April, .2015 to the following:

Nicolas LaHood

District Attorney

Jay Brandon

Assistant District Attorney

Paul Elizondo Tower

101 West Nueva, Fo~rth Floor

San Antonio, Texas 78205

E-mail: jay.brandon@bexar.org,

__ Is/Cynthia£. Orr __ __ _ _