McFatridge, 2011 WL 1334400, at *3; Harris, 287 S.W.3d at 792; Tamez, 205 S.W.3d at 39. Even with a request, however, a trial court order was necessary before the State was required to timely disclose its expert witnesses. McFatridge, 2011 WL 1334400, at *3; Harris, 287 S.W.3d at 792; Tamez, 205 S.W.3d at 39-40); see Williams v. State, No. 04-06-00797-CR, 2007 WL 3171335, at *2 (Tex. App.—San Antonio Oct. 31, 2007, no pet.) (mem. op., not designated for publication) ("[T]he State's obligation to disclose its expert witnesses under article 39.14(b) of [the] Code of Criminal Procedure is triggered only by a court order."); see also In re Tibbe, No. 03-13-00741-CV, 2013 WL 6921525, at *2 (Tex. App.—Austin Dec. 31, 2013, orig. proceeding) ("[U]nder its plain language, the disclosure provision of article 39.14(b) is triggered only by a defendant's motion requesting disclosure of the State's testifying experts and a trial court order.") (emphasis added). In 2015, the Legislature amended article 39.14(b) to require a party receiving a request for disclosure of expert witnesses to provide the information to the requesting party based on the request alone without an order from the trial court.

Prior to September 1, 2015, the State's duty was "triggered only by a defendant's motion requesting disclosure of the State's testifying experts and a trial court order." In re Tibbe, No. 03-13-00741-CV, 2013 WL 6921525, at *2 (Tex. App.-Austin Dec. 31, 2013, orig. proceeding) (mem. op.) (emphasis added). Article 39.14(b) no longer requires a trial court order; the defendant's request alone trigger's the State's duty to disclose.

"[U]nder its plain language, the disclosure provision of article 39.14(b) is triggered only by a defendant's motion requesting disclosure of the State's testifying experts and a trial court order." In re Tibbe, No. 03-13-00741-CV, 2013 WL 6921525, at *2 (Tex. App.—Austin Dec. 31, 2013, orig. proceeding) (mem. op.) (emphasis added). Because the trial court never ruled on Byrd's motion, he was not entitled to the twenty-day notice contemplated by article 39.14. Id.; see Palomino v. State, No. 14-10-00926-CR, 2011 WL 6578391, at *6 (Tex. App.—Houston [14th Dist.] Dec. 20, 2011, no pet.) (mem. op., not designated for publication) ("A party must procure a ruling from the trial court on a motion to disclose expert witnesses in order to preserve error."); Tamez v. State, 205 S.W.3d 32, 39 (Tex. App.—Tyler 2006, no pet.) ("[A]rticle 39.14(b) allows the trial court to require the State to list their expert witnesses upon request.