ACCEPTED
04-16-00133-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
8/31/2016 2:11:03 PM
KEITH HOTTLE
CLERK
IN THE COURT OF APPEALS
FOR THE FOURTH APPELLATE DISTRICT OF TEXAS
SAN ANTONIO, TEXAS FILED IN
4th COURT OF APPEALS
SAN ANTONIO, TEXAS
JAMES CLINTON COYLE, § 08/31/2016 2:11:03 PM
Appellant, § KEITH E. HOTTLE
§ Clerk
VS. § NO. 04-16-00133-CV
§
COYLE FAMILY FARM, INC., §
Appellee. §
ON APPEAL FROM
CAUSE NO. 3208
COUNTY COURT AT LAW,
MEDINA COUNTY, TEXAS
HONORABLE VIVIAN TORRES, JUDGE PRESIDING
APPELLANT’S MOTION FOR LEAVE TO FILE APPELLANT’S
SUPPLEMENTAL BRIEF WITH BRIEF ATTACHED
ANTON E. HACKEBEIL
State Bar No. 08667150
P.O. Box 220
Hondo, Texas 78861
Tel: (830) 741-7001
Fax: (866) 743-4537
Email: tonyhackebeil@att.net
ATTORNEY FOR APPELLANT
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
COMES NOW Appellant, James Clinton Coyle, by and through the
undersigned counsel and files this Motion for Leave to File Appellant’s
Supplemental Brief with Brief Attached, and would show the court the following:
Counsel for Appellant would show that counsel failed to include in
Appellant’s Brief an argument critical to sustain Appellant’s plea to this court that
is contained in the Mediated Settlement Agreement (“MSA”) referred to in and
attached to Appellant’s Brief which Appellant’s counsel believes could eliminate the
need for argument on other points in Appellant’s Brief but without abandoning
Appellant’s original Brief.
Appellant’s Supplemental Brief is attached to this motion and is short and
concise in identifying a provision in the MSA that Appellant’s counsel believes
should eliminate the need for additional arguments and reliance on legal theories
since the very document upon which Appellee relies for its requested relief precludes
Appellee from pursuing any action with regard to a dispute of terms of the MSA in
any forum except the District Court of the 38th Judicial District.
Wherefore, premises considered, Appellant prays that this court grant his
Motion for Leave to file Appellant’s Supplemental Brief and accept Appellant’s
Brief as attached to this Motion.
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Respectfully submitted,
/s/ Anton E. Hackebeil
ANTON E. HACKEBEIL
State Bar No. 08667150
P.O. Box 220
Hondo, Texas 78861
Tel: (830) 741-7001
Fax: (866) 743-4537
Email: tonyhackebeil@att.net
ATTORNEY FOR APPELLANT
CERTIFICATE OF COMPLIANCE
I certify that this document complies with the typeface requirements of Tex.
R. App. P. 9.4(e) because it has been prepared in a conventional typeface no smaller
than 14-point font for text, 12-point for footnotes. I also certify that this document
contains approximately 440 words.
/s/ Anton E. Hackebeil
Anton E. Hackebeil
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CERTIFICATE OF SERVICE
This is to certify that on August 31, 2016, a true and correct copy of
Appellant’s Motion for Leave to File Supplemental Brief with Brief Attached was
served on John C. Chunn, attorney for Appellee, P.O. Box 396, Hondo, Texas 78861,
by electronic filing manager.
/s/ Anton E. Hackebeil
Anton E. Hackebeil
Counsel for Appellant
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