PD-0599-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS December 11, 2015 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 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,

/s/ Bruce Anton BRUCE ANTON Bar Card No. 01274700 [email protected]

/s/ Brett Ordiway BRETT ORDIWAY Bar Card No. 24079086 [email protected]

SORRELS, UDASHEN & ANTON 2311 Cedar Springs Road Suite 250 Dallas, Texas 75201 (214)-468-8100 (office) (214)-468-8104 (fax)

Attorneys for Petitioner-Appellee 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.

/s/ Bruce Anton BRUCE ANTON Bar Card No. 01274700 [email protected]