Justin Sanders v. State

ACCEPTED 06-14-00079-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS 6/3/2015 4:17:06 PM

DEBBIE AUTREY

CLERK IN THE COURT OF APPEALS

SIXTH JUDICIAL DISTRICT OF TEXAS

AT TEXARKANA FILED IN

6th COURT OF APPEALS TEXARKANA, TEXAS

JUSTIN SANDERS, 6/3/2015 4:17:06 PM

Appellant DEBBIE AUTREY

Clerk vs. Appellate Cause No. 06-14-00079-CR THE STATE OF TEXAS,

Appellee

APPELLANT'S MOTION FOR LEAVE TO FILE SUPPLEMENTAL BRIEF

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

COMES NOW the Appellant in the above styled and numbered cause and respectfully moves the Court in accordance with Tex. R. App. Pro. Rule 38.7 for leave to file Appellant’s Supplemental Brief and in support therefore would respectfully show unto the Court as follows:

1. During oral argument Justice Moseley asked who bore the burden to demonstrate attenuation of taint on a suppression issue and Justice Carter asked how the court should proceed in determining if the search warrant was sufficient to attenuate taint from a prior illegality.

2. Appellant has conducted additional research on those issues and believes the filing of a short supplemental brief will aid the court in making a correct determination of the issues.

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests this Honorable Court grant leave to file Appellant’s Supplemental Brief in this cause.

Respectfully submitted, CRAIG L. HENRY Attorney at Law 723 Main Street P.O. Box 3226 Texarkana, Texas 75504-3226 (903) 792-4645 FAX - (903) 792-5073 [email protected] By/s/ Craig L. Henry

Craig L. Henry Arkansas Bar # 90142 Oklahoma Bar # 016779 Texas Bar # 09479260 Attorney for Appellant

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing Motion has been delivered electronically and via courier to Mr. Jerry Rochelle, Bowie County District Attorney, 601 Main Street, Texarkana, Texas 75501, this 3rd day of June, 2015.

/s/ Craig L. Henry Craig L. Henry