Case Information
*0 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 4/17/2015 5:48:09 PM KEITH E. HOTTLE Clerk *1 ACCEPTED 04-014-00494-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 4/17/2015 5:48:09 PM KEITH HOTTLE CLERK NO. 04-014-00494-CV IN THE FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS UNITED PARCEL SERVICE, INC. and ROLAND LEAL
Appellants/Cross-Appellees v.
ROBERT SCOTT RANKIN, Individually; RACHELLE RANKIN,
Individually and as Next Friend for AVERY RANKIN, a Minor; as Next
Friend for KARA RANKIN, a Minor; and as Next Friend for SAMUEL
RANKIN, a Minor Appellees/Cross-Appellants th On Appeal from the 224 Judicial District Court, Bexar County, Texas
Honorable Cathy Stryker, Presiding Judge
Trial Court Cause No. 2011-CI-07922 CROSS-APPELLANTS’ UNOPPOSED MOTION FOR LEAVE TO FILE
REPLY TO CROSS-APPELLEES’ SURREPLY TO ARGUMENT IN
CROSS-APPELLANTS’ REPLY BRIEF THAT RULE 167.4(a) IS INVALID TO THE HONORABLE COURT OF APPEALS:
Cross-Appellants, Robert Scott Rankin, Rachelle Rankin, Avery Rankin, Kara
Rankin, and Samuel Rankin (the “Rankins”), by and through their undersigned
*2 attorneys, hereby move the Court for an Order allowing them to file a Reply to Cross-
Appellees’ Surreply to Argument in Cross-Appellants’ Reply Brief That Rule
167.4(a) is Invalid, and in support thereof would respectfully show the Court the
following:
The Court granted Cross-Appellees’ Motion for Leave to File Reply to New
Argument in Cross-Appellants’ Reply Brief That Rule 167.4(a) is Invalid on April 14,
2015. Cross-Appellants request that the Court allow them to file their Reply to
Cross-Appellees’ Surreply in that it will assist the Court by providing argument and
authority. Cross-Appellees are not opposed to Cross-Appellants’ Motion for Leave.
WHEREFORE , Cross-Appellants pray that this Court grant them leave to file
their reply to Cross-Appellees’ Surreply to Argument in Cross-Appellants’ Reply
Brief That Rule 167.4(a) is Invalid, which is being electronically filed simultaneously
with this Motion, and for such other and further relief as the Court may deem to be
just and proper.
*3 Respectfully submitted, THE PERRIN LAW FIRM 1910 Pacific Avenue, Suite 6050 Dallas, Texas 75201 Telephone: (214) 646-2004 Facsimile: (214) 646-6117 Email: dougperrin@perrinlaw.org markperrin@perrinlaw.org /s/J. Mark Perrin Doug Perrin State Bar No. 15796520 J. Mark Perrin State Bar No. 24013313 REESE GORDON MARKETOS LLP 750 N. St. Paul Street, Suite 610 Dallas, Texas 75201 Telephone: (214) 382-9810 Facsimile: (214) 501-0731 Email: pete.marketos@rgmfirm.com Pete Marketos State Bar No. 24013101 KEELING & DOWNES, P.C. 1500 McGowen Street Houston, Texas 77004 Telephone: (832) 214-9900 Fax: (832) 214-9908 Email: bck@keelingdownes.com Byron Keeling State Bar No. 11157980 ATTORNEYS FOR CROSS-APPELLANTS *4 CERTIFICATE OF CONFERENCE
I have conferred with counsel for Cross-Appellees about the merits of this
Motion and was advised that Cross-Appellees do not oppose the relief requested in
this Motion. th
Certified this 17 day of April, 2015.
/s/J. Mark Perrin J. Mark Perrin CERTIFICATE OF SERVICE
This will certify that a true and correct copy of the above and foregoing
document was forwarded to all counsel of record in the above cause through the th
Court’s electronic case filing system, on this the 17 day of April, 2015.
Ricardo Reyna
Audrey Haake
Brock, Person, Guerra, Reyna P.C.
17339 Redland Road
San Antonio, Texas 78247
W. Randall Bassett
Bradley Pratt
King & Spalding, LLP
1180 Peachtree Street, NE
Atlanta, Georgia 30309
H. Victor Thomas
King & Spalding, LLP
1100 Louisiana, Suite 4000
Houston, Texas 77002
/s/J. Mark Perrin