PEOPLE v. COVARRUBIAS (DANIEL SANCHEZ)Appellant’s Additional Authorities LetterCal.May 23, 2016SUPREME COURT COPY THOMAS LUNDY Attorney at Law 2777 Yulupa Avenue, PMB 179 Criminal Appellate Practice Santa Rosa, California 95405 Fax (707) 538-0125 (707) 538-0175 tundy@juryinstruction.com May 20, 2016 SUPREME COURT Honorable Frank A. McGuire Court Administrator and Clerk Supreme Court of California MAY 23 2016 350 McAllister Street San Francisco, California 94102 Frank A. McGuire Clerk RE People v. Daniel Sanchez Covarrubias Deputy California Supreme Court Case No.S075136 Additional Authorities Letter Dear Mr. McGuire: Counsel may refer to one or more of the following additional authorities during argument currently calendared for June 1, 2016 at 2:00 PM: Re: AOB Claim I People v. Leon (2015) 61 Cal.4th 569 Re: AOB Claim 10 Ocampo v. Vail (9th Cir. 2011) 649 F.3d 1098, 1115.) [“The Supreme Court has long recognized that accomplices are questionable witnesses.”] People v. Bryant (2011) 198 Cal.App.4th 134, 153-154 [“Viewing the evidenceinthelight most favorable to Bryant, as is required [citation] we conclude that there is substantial evidence from whicha reasonablejury could find that Bryantdid not subjectively appreciate that her conduct endangered Robert's life...the jury could have believed Bryant's testimony that she never intendedto kill Robert.”] Re: AOB Claim 53 People v. Banks (2015) 61 Cal.4th 788 C I 4 ba t a i n s e a y S oPENALTY Yours very truly, Thomas Lundy Attorney for Appellant Daniel Sanchez Covarrubias PROOF OF SERVICE I DECLARE THAT: I am a resident of Sonoma County and employed in the County of Sonoma, State of California. I am overthe age ofeighteen and nota party to the within action. My business address is: 2777 Yulupa Avenue PMB 179, Santa Rosa, California 95405. On May20, 2016, I served the within: Additional Authorities Letter on the interested parties in said cause, by placing a true copy thereof enclosedin a sealed envelope with first class postage thereon, fully prepaid, in the United States mail, at Santa Rosa, California, addressed as follows: Bridgette Billeter Office of the Attorney General 455 Golden Gate Avenue, Suite 11000 San Francisco, CA 94102-7004 California Appellate Project 101 Second Street, Suite 600 San Francisco, CA 94105 Daniel Sanchez Covarrubias P-19600 CSP-SQ 4-EY-35 San Quentin, CA 94974 I declare under penalty ofperjury that the foregoingis true and correct and executed on May20, 2016 at Santa Rosa, California. Tom Lundy
