PD-0122-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 8/25/2015 10:25:01 AM Accepted 8/25/2015 10:28:31 AM IN THE COURT OF CRIMINAL APPEALS ABELAC°erk OF TEXAS

FILED IN COURT OF CRIMINAL APPEALS ERIC DWAYNE STEVENSON, August 25, 2015 APPELLANT R ABELACOSTA, CLERK V. § NO. PD-0122-15 THE STATE OF TEXAS, § APPELLEE §

STATE'S MOTION FOR LEAVE TO FILE A POST-SUBMISSION SUPPLEMENTAL BRIEF

TO THE HONORABLE COURT OF CRIMINAL APPEALS:

COMES NOW, the State of Texas, pursuant to Texas Rule of Appellate Procedure 70.4, and files this motion for leave to file a post-submission supplemental brief. In support of its motion, the State would show the Court the following:

Both parties have filed their briefs and this cause was submitted on August 5, 2015.

II.

The State requests leave to file a supplemental brief in order to apprise the Court of recent changes by the Texas Legislature to the statutory language for criminally prosecuting sexually violent predators for violating their civil commitment requirements which impact the appellant's convictions. See 2015 Tex. Sess. Law Serv. Ch. 845 (S.B. 746) §13 (to be codified at Tex. Health & Safety Code Ann. § 841.082(a)) & 2015 Tex. Sess. Law Serv. Ch, 845 (S.B. 746) §19 (to be codified at Tex. Health & Safety Code Ann. §841.085(a)).

WHEREFORE, PREMISES CONSIDERED, the State prays that the Court grant this motion for leave to file the State's post-submission supplemental brief and that the Court file the State's post-submission supplemental brief.

Respectfully submitted, SHAREN WILSON Criminal District Attorney Tarrant County, Texas DEBRA WINDSOR Chief, Post-Conviction /s/ Steven W. Conder Criminal District Attorney W. Belknap Fort Worth, Texas 76196-0201 (817)884-1687 FAX (817) 884-1672 State Bar No. 04656510 [email protected]

CERTIFICATE OF SERVICE

True copies of the State's post-submission supplemental brief have been electronically served on opposing counsel, the Hon. Scott Walker (scott(5)lawverwalker.com), 222 W. Exchange Avenue, Fort Worth, Texas 76164; and the State Prosecuting Attorney, the Hon. Lisa McMinn ([email protected]), P.O. Box 13046, Austin, Texas 78711-3046, on this, the 25th day of August, 2015.

/s/ Steven W. Conder STEVEN W. CONDER

d 8.Stevenson eric dwayne.mi/leave to supplement