Case Information
*1 PD-0599-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 12/10/2015 3:48:48 PM Accepted 12/11/2015 8:51:48 AM ABEL ACOSTA PD-0599-15 CLERK MARK TWAIN SIMPSON § IN THE TEXAS
§
v. § COURT OF
§ THE STATE OF TEXAS § CRIMINAL APPEALS
PETITIONER’S MOTION FOR LEAVE
OF COURT TO FILE REPLY BRIEF
TO THE HONORABLE JUDGES OF SAID COURT:
NOW COMES Petitioner-Appellee Mark Twain Simpson, and submits this motion for leave of court to file a reply brief. In support thereof, Simpson would show the following:
I. Simpson filed a brief in the above-listed matter in this Court on November 9, 2015. On December 9, 2015, the State filed its response.
II. The State’s brief does not address the issue raised in Simpson brief. Instead, the State again attempts to re-litigate the issue already properly decided by the trial court. Simpson’s reply brief both clarifies this for this Court and explains why the State’s failure to address the *2 issue raised in Simpson’s brief reveals its merit.
Accordingly, Appellant prays that this motion for leave of court to file reply brief be granted.
Respectfully submitted,
B A NTON
Bar Card No. 01274700
/s/ Brett Ordiway
RETT O RDIWAY
bordiway@sualaw.com
S ORRELS , U DASHEN & 2311 Cedar Springs Road Suite 250
Dallas, Texas 75201
(214)-468-8100 (office)
(214)-468-8104 (fax)
Attorneys for Petitioner-Appellee *3 Certificate of Service
I, the undersigned, hereby certify that a true and correct copy of the foregoing Appellant’s Motion for Leave of Court to File Reply Brief was electronically served to the Dallas County District Attorney’s Office and the State Prosecuting Attorney on December 10, 2015.