FILED IN PD-0622-14 COURT OF CRIMINAL APPEALS COURT OF CRIMINAL APPEALS AUSTIN, TEXAS January 21, 2014 Transmitted 1/21/2015 3:49:56 PM Accepted 1/21/2015 3:52:49 PM ABEL ACOSTA, CLERK ABEL ACOSTA Nos. PD-0601-14 & PD-0622-14 CLERK

TO THE COURT OF CRIMINAL APPEALS

OF THE STATE OF TEXAS

CLAYTON DEAN REEDER AND /Appellants MARCUS BRUCE HOLIDY, lb v.

THE STATE OF TEXAS, Appellee

Appeals from Rusk County

STATE'S MOTIONS FOR LEAVE TO FILE POST-SUBMISSION SUPPLEMENTAL BRIEFS

LISA C. McMINN State Prosecuting Attorney Bar I.D. No. 13803300

STACEY M. GOLDSTEIN Assistant State Prosecuting Attorney Bar I.D. No. 24031632

P.O. Box 13046 Austin, Texas 78711 [email protected] 512-463-1660 (Telephone) 512-463-5724 (Fax) TO THE HONORABLE COURT OF CRIMINAL APPEALS:

The State Prosecuting Attorney respectfully presents her motion for leave to file Post-Submission Supplemental Briefs under Texas Rule of Appellate Procedure 70.4. The State believes that it is necessary to respond to, and further address, issues raised during oral argument.

PRAYER FOR RELIEF

WHEREFORE, the State of Texas prays that the Court of Criminal Appeals grant it leave to file its Post-Submission Supplemental Briefs.

Respectfully submitted, /s/ STACEY M. GOLDSTEIN Assistant State Prosecuting Attorney Bar I.D. No. 24031632

P.O. Box 13046 Austin, Texas 78711 [email protected] 512-463-1660 (Telephone) 512-463-5724 (Fax) CERTIFICATE OF SERVICE

The undersigned certifies that a copies of the State's Motions for Leave to File Post-Submission Supplemental Briefs have been served on January 21, 2015, via certified electronic service provider to: Hon. Richard Kennedy Rusk County Courthouse North Main'Street Henderson, Texas 75652 [email protected]

Hon. Ebb B. Mobley North Center Street P.O. Box 2309 Longview, Texas 75606 [email protected]

Isi STACEY M. GOLDSTEIN Assistant State Prosecuting Attorney