Case Information
*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 5/12/2015 4:42:07 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-14-00492-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 5/12/2015 4:42:07 PM CHRISTOPHER PRINE CLERK IN THE FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
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NO. 14-14-00492-CV
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PAUL STAMATIS, JR., AS INDEPENDENT EXECUTOR OF THE
ESTATE OF PAUL STAMATIS, DECEASED, Appellant
V.
METHODIST WILLOWBROOK HOSPITAL, DANIEL MAO, M.D., AND
NEPTUNE EMERGENCY SERVICES, P.A., Appellees th On Appeal from the 190 District Court
Harris County, Texas Trial Court Cause No. 2010-34910 APPELLANT’S MOTION FOR LEAVE TO FILE ITS REBUTTAL TO
APPELLEE’S POST-SUBMISSION BRIEF Respectfully submitted,
T HE EWIS L
/s/ J. Craig Lewis
J. Craig Lewis
State Bar No. 12283500
2905 Sackett Street.
Telephone: 713.238.7715
Facsimile: 713.238.7888
Email: jenniferb@LLF7.com
ATTORNEYS FOR APPELLANT
TO THE HONORABLE COURT OF APPEALS:
Appellant, Paul Stamatis, Jr. files this Motion for Leave to File its Post-
Submission Rebuttal to Appellee’s Post-Submission Brief.
Appellant seeks leave to file its Post-Submission Rebuttal submitted
concurrently herewith to respond to the Post-Submission Brief filed by the Appellees
on May 7, 2015. The Appellees sought leave from this Court to file their Post-
Submission Brief because at oral argument on April 30, 2015, they did not have
adequate enough time to respond to questions posed by the Justices of the Panel. Had
the Appellees responded to the Justices of the Panel at oral argument, Appellant
would have rebutted the Appellees on the manner set forth in this Rebuttal. Based
on Appellant’s Post-Submission Rebuttal to the Appellees’ Post-Submission Brief,
Appellant believes that its Rebuttal will assist the Court in its deliberations
PRAYER FOR RELIEF
For the reasons set forth above, Appellant requests that this Court grant his
Motion for Leave to File Post-Submission Rebuttal, direct the clerk to accept and file
Appellant’s Post-Submission Rebuttal, and grant him all other relief to which he may
be entitled.
[signature page follows]
Respectfully submitted, T HE L EWIS L F /s/ J. Craig Lewis J. Craig Lewis
State Bar No. 12283500 2905 Sackett Street Telephone: 713.238.7715 Facsimile: 713.238.7888 Email: jenniferb@LLF7.com ATTORNEYS FOR APPELLANT CERTIFICATE OF CONFERENCE As required by Texas Rule of Appellate Procedure 10.1(a)(5), I certify that I
have conferred with opposing counsel, listed below, about the merits of this motion
with the following results:
Oscar De la Rosa, with the D E LA R OSA AW IRM , attorney for
Appellee, Methodist Willowbrook Hospital, does not oppose motion.
LaVerne Chang, with C ARDWELL & C HANG , attorney for Appellees,
Daniel Mao, M.D. and Neptune Emergency Services, P.A., does not
oppose motion. Dated: May 12, 2015 /s/ Craig Lewis
J. Craig Lewis *4 CERTIFICATE OF SERVICE th This is to certify that on this 12 day of May, 2015 a true and correct copy of
the foregoing instrument was served upon opposing counsel via e-serve. I further
certify that I have complied with the provisions of Rules 21 and 21a of the Texas
Rules of Civil Procedure.
Ms. LaVerne Chang Via E-Serve
C ARDWELL & C HANG
511 Lovett Boulevard
Houston, Texas 77006
Counsel for Appellees, Daniel Mao, M.D. and Neptune Emergency Services, P.A.
Mr. Oscar De la Rosa Via E-Serve
D E LA R OSA
Three Riverway, Suite 1820
Counsel for Appellee, Methodist Willowbrook Hospital
/s/ J. Craig Lewis J. Craig Lewis
ATTORNEY FOR APPELLANT, PAUL STAMATIS, JR., AS INDEPENDENT EXECUTOR OF THE ESTATE OF PAUL STAMATIS, DECEASED