by and through counsel on appeal, seeks leave to file his Post-Submission Brief for Appellant. Appellant seeks to provide further briefing based upon the questions posed by the Court at oral argument. In support of his prayer for reversal he would respectfully show the Court the following:

I. Appellant was convicted of capital murder. This Court granted oral argument, which was received on October 7, 2015. No opinion has yet been issued.

II. Many members of the Court posed questions at oral argument that were not capable of being answered by reference to Appellant's original brief. Appellant has briefed these questions in a post-submission brief. The post-submission brief has been submitted contemporaneously with this motion.

III. Upon motion by a party, this Court may permit the filing of additional briefs other than those provided for in Rule 38. See Tex. R. App. Proc. 71.4.

PRAYER FOR RELIEF FOR THESE REASONS, the Appellant prays the Honorable Court of Criminal Appeals will grant this motion and order Appellant's post-submission brief filed amongst the papers in the cause.

Respectfully submitted, By:

917 Franiklin, Suite 320 ShearerLegal@Yahoo. com *4 CERTIFICATE OF SERVICE

I certify that a copy of this Motion for Leave to File Post-Submission Brief for Appellant has been served upon the State of Texas by e-mailing a copy of same to the following parties at their respective addresses on this the 7th day of November, 2015:

A.D.A. CLINTON A. MORGAN

DISTRICT ATTORNEY'S OFFICE

APPELLATE DIVISION

1201 FRANKLIN, SUITE 600

HOUSTON, TX 77002

Morgan_Clionton@dao. hctx. net