PEOPLE v. WINBUSH (GRAYLAND) (To be called and continued to the November 2016 calendar.)

Respondent’s Additional Authorities Letter

Cal.August 17, 2016

SUPREME COURT COPY KAMALA D. HARRIS CS©P\V/ State ofCalifornia Attorney General DEPARTMENTOFJUSTICE 455 GOLDEN GATE AVENUE,SUITE 11000 SAN FRANCISCO, CA 94102-7004 Public: Telephone: (415) 703-5550 Facsimile: (415) 703-1234 E-Mail: Karen.Bovarnick@doj.ca.gov “3 703-5500 August 17, 2016 SUPREME Cour a T Frank A. McGuire F | L ED Supreme Court Clerk/Administrator _ Supreme Court of the State of California AUG 17 2016 350 McAllister Street San Francisco, CA 94102-4797 Frank A - McGuire Cl‘ erk RE: People v. Grayland Winbush es Deputy . Supreme Court of the State of California, Case No. $117489 Dear Mr. McGuire: Oral argumentin this matter is set for Thursday, September 8, 2016 at 9:00 a.m. We wish to bring to the Court’s attention a new authority issued subsequentto briefing. Respondent will be prepared to address People v. Salazar (2016) 63 Cal.4th 214, 233-238 [no duty to rehabilitate prospective juror that is unable to impose a death sentence and defense forfeited claim of error stemming from trial court’s “failure to ask any particular question”], relevantto Issue III (challenge for cause). Sincerely, / , ‘ KARENZ.at Deputy Attorney General For KAMALAD. HARRIS Attorney General KZB:tn SF2003XS0002 20885692.doc cDEATH PENALTY DECLARATION OF SERVICE BY U.S. MAIL Case Name: People v. Winbush No.: S117489 I declare: Iam employed in the Office of the Attorney General, which is the office of a memberof the California State Bar, at which member's direction this service is made. I am 18 years of age or older and not a party to this matter. I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United States Postal Service. In accordance with that practice, correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service with postage thereon fully prepaid that same day in the ordinary course of business. On August 17, 2016, I served the attached LETTER DATED AUGUST17, 2016, TO FRANK A. MCGUIRE, SUPREME COURT CLERK/ADMINISTRATORbyplacing a true copy thereof enclosed in a sealed envelope in the internal mail collection system at the Office of the Attorney General at 455 Golden Gate Avenue, Suite 11000, San Francisco, CA 94102-7004, addressed as follows: Richard Jay Moller County of Alameda Attorney at Law Criminal Division - Rene C. Davidson P.O. Box 1669 Superior Court of California Redway, CA 95560-1669 1225 Fallon Street, Room 107 Oakland, CA 94612-4293 The Honorable Nancy O'Malley District Attorney California Appellate Project (SF) Alameda County District Attorney's Office 101 Second Street, Suite 600 1225 Fallon Street, Room 900 San Francisco, CA 94105-3647 Oakland, CA 94612-4203 I declare under penalty of perjury under the laws of the State of California the foregoingis true and correct and that this declaration was executed on August 17, 2016, at San Francisco, California. Tan Nguyen caNYYLf.E— Declarant Pignatufe SF2003XS0002 20887468.doc