Comes now, Appellant Todd Enright and files this Unopposed Motion for

Leave to File Pre-Submission Letter. In support thereof, Todd Enright would show

the Court as follows:

1. This case is set for oral argument on November 4, 2015.

2. Appellant Todd Enright seeks leave to file a three-page pre-

submission letter for the purpose of focusing the Court’s attention on particular

points that will be made at oral argument. In requesting permission to file this

letter, Mr. Enright does not seek to burden the Court but, rather, to assist the Court

in its disposition of this appeal.

3. Appellees do not oppose the relief requested by this motion.

PRAYER

Appellant Todd Enright prays that the Court grant this Unopposed Motion

for Leave to File Pre-Submission Letter and grant Todd Enright leave to file a pre-

submission letter with this Court.

Respectfully submitted,

VINSON & ELKINS LLP

/s/ Jennifer B. Poppe Thomas S. Leatherbury State Bar No. 12095275 2001 Ross Avenue, Suite 3700 Dallas, Texas 75201 Telephone: (214) 220-7700 Facsimile: (214) 999-7792 tleatherbury@velaw.com Jennifer B. Poppe State Bar No. 24007855 State Bar No. 24059921 Jonah Jackson State Bar No. 24071450 2801 Via Fortuna, Suite 100 Austin, Texas 78746 Telephone: (512) 542-8400 Facsimile: (512) 542-8612 jpoppe@velaw.com jjackson@velaw.com Attorneys for Appellant Todd Enright

CERTIFICATE OF CONFERENCE

On October 30, 2015, I conferred with Appellees’ attorney Paul Matula and

was informed that Appellees do not oppose the relief requested by this motion.

/s/ Michael A. Heidler

*4 CERTIFICATE OF SERVICE

On October 30, 2015, a true and correct copy of the foregoing document was

served on the following attorneys via electronic filing:

Eric J. Taube

Paul Matula

Taube Summers Harrison Taylor Meinzer Brown, LLP

100 Congress Avenue, 18th Floor

Austin, Texas 78701

etaube@taubesummers.com

pmatula@taubesummers.com

/s/ Michael A. Heidler