Case Information
*1 PD-1067-15 FILED IN COURT OF CRIMINAL APPEALS COURT OF CRIMINALAPPEALS AUSTIN, TEXAS Transmitted 11/23/2015 3:54:41 PM
N. Q . Qr Oo oni(- Accepted 11/23/2015 4:04:21 PM November 23,2015 K ARP, arnqT, ABEL ACOSTA NO. PD-1067-15 CLERK ABEL ACOSTA, CLERK IN THE /frv>^*& "
COURT OF CRIMINAL APPEALS OF TEXAS Q ,£,, EX PARTE JAMES RICHARD "RICK" PERRY, I\ " 21 "^
Appellant
On Appeal from the 390th Judicial District Court, Travis County, Texas, Cause No. D-l-DC-14 100139 APPELLANT'S MOTION FOR LEAVE TO FILE
POST-ORAL ARGUMENT SUBMISSION IN CONNECTION WITH HIS BRIEF ON THE MERITS ADDRESSING HIS PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE JUDGES OF SAID COURT:
COMES NOW Appellant, James Richard "Rick" Perry (Governor Perry), and pursuant to Tex.R. App.P. 71.4, seeks leave of Court to file a brief, post-oral argument submission.
As the Court is aware, oral argument was presented on November 18, 2015. Governor Perry desires to file a brief, post-oral argument submission in order to provide cases which were discussed, but not specifically identified during the oral argument. Furthermore, precise page references to all of the State's judicial admissions appear to be necessary and appropriate.
WHEREFORE, PREMISES CONSIDERED, Governor Perry prays that this *2 Court grant this motion and allow the filing of his post-oral argument submission.
Respectfully submitted, /s/David L. Botsford
David L. Botsford
State Bar No. 02687950 1307 West Ave.
Austin, Texas 78701
dbotsford@aol.com
Telephone: 512-479-8030 Facsimile: 512-479-8040 THE BUZBEE LAW FIRM /s/ Anthony G. Buzbee Anthony G. Buzbee
State Bar No. 24001820 JPMorgan Chase Tower 600 Travis Street, Suite 7300 Houston, Texas 77002 Tbuzbee@txattorneys.com Telephone: 713-223-5393 Facsimile: 713-223-5909 BAKER BOTTS L.L.P.
/s/ Thomas R. Phillips
Thomas R. Phillips
State Bar No. 00000102 98 San Jacinto Blvd., Suite 1500 Austin, Texas 78701-4078 tom.phillips@bakerbotts.com Telephone: 512-322-2565 Facsimile: 512-322-8363 *3 Certificate of Service
I hereby certify that a true and correct copy of the above and foregoing has been delivered to all counsel at the time it was electronically filed.
/s/ David L. Botsford