ACCEPTED 04-14-00915-cr FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 8/31/2015 4:49:53 PM KEITH HOTTLE CLERK IN THE FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS Adan Flores v. The State of Texas 08/31/2015 4:49:53 PM KEITH E. HOTTLE Clerk NO. 04-14-00915-CR Trial Court No. 2014CRS000311-D1

STATE’S MOTION FOR LEAVE TO FILE ADDITIONAL CITATIONS

TO THE HONORABLE JUSTICES OF SAID COURT: NOW COMES THE STATE OF TEXAS, and respectfully moves the Court to permit the filing of the attached additional citations and commentary in support of the State’s Brief. Although Local Rule 8.3 permits the filing of additional citations and succinct commentary without leave of the Court, and the attached document consists only of citations and commentary, it totals 25 pages and 5,449 words due to the sheer number of cases summarized: there are fifteen fully summarized cases (for and against the State’s position), two tables of further citations, and about a page and a half of summarizing commentary. Therefore, out of an abundance of caution, the State requests leave to file the attached document as if it was a supplemental brief under Local Rule 8.4.

STATE’S ADDITIONAL CITATIONS PAGE 1 OF 3 PRAYER WHEREFORE, PREMISES CONSIDERED, the State prays the Court grant leave to file the attached document.

Respectfully submitted, ISIDRO R. ALANIZ DISTRICT ATTORNEY 49TH JUDICIAL DISTRICT By:___/s/__________________ David L. Reuthinger, Jr. Assistant District Attorney Webb County, 49th Judicial District 1110 Victoria St., Suite 401 Laredo, Texas 78040 (956) 523-4900 / (956) 523-5070 (Fax) Bar No. 24053936 ATTORNEY FOR APPELLEE

STATE’S ADDITIONAL CITATIONS PAGE 2 OF 3 CERTIFICATE OF COMPLIANCE The word count of the foregoing document is 148.

Date: August 31, 2015

___/s/__________________ David L. Reuthinger, Jr. Attorney for Appellee

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing document has been delivered to Armando Trevino, attorney for the Appellant, via eFileTexas e-Service to [email protected]

Date: August 31, 2015.

___/s/__________________ David L. Reuthinger, Jr. Attorney for Appellee

STATE’S ADDITIONAL CITATIONS PAGE 3 OF 3