ACCEPTED
03-14-00016-CV
3604657
THIRD COURT OF APPEALS
AUSTIN, TEXAS
12/29/2014 2:53:54 PM
JEFFREY D. KYLE
CLERK
No. 03-14-00016-CV
________________________________________
FILED IN
3rd COURT OF APPEALS
IN THE COURT OF APPEALS AUSTIN, TEXAS
FOR THE THIRD DISTRICT OF TEXAS 12/29/2014 2:53:54 PM
AUSTIN, TEXAS JEFFREY D. KYLE
__________________________________________ Clerk
WILLIAM CULLEN CHAMPION
Appellant,
v.
MARILYN ESTLOW
Appellee.
______________________________________________
On Appeal from the County Court at Law Number One
of Travis County, Texas
________________________________________________
UNOPPOSED MOTION FOR LEAVE
TO FILE POST-SUBMISSION LETTER BRIEF
________________________________________________
William Cullen Champion, Appellant herein, files this unopposed motion for
leave to file a post-submission letter brief. Appellant respectfully requests that this
Court accept a post-submission letter brief limited to a single issue raised by the
Court in oral argument. In support of this request, Appellant would show the
following:
1. The Court heard oral argument in this case on December 17, 2014.
2. At oral argument, Justice Pemberton raised a question regarding the issue
of waiver of venue objections in a no-answer default judgment. This issue was not
discussed in Appellant’s Brief.
3. Appellant has prepared a short post-submission letter brief addressing
this issue. The letter brief is attached hereto as Exhibit A. Appellant requests
leave to file this letter brief so that the Court may consider the arguments and legal
authorities contained therein.
4. Appellee does not oppose the granting of the motion for leave.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court
grant its motion for leave and that the post-submission letter brief attached hereto
as Exhibit A be filed with the papers in this case. Appellant also requests such
other and further relief to which it may be entitled.
Respectfully submitted,
BOURLAND LAW FIRM, P.C.
1 Chisholm Trail, Suite 150
Round Rock, Texas 78681
(512) 477-0100
(512) 477-0154 (facsimile)
BY: /s/ Anna Eby______________
CINDY OLSON BOURLAND
State Bar No. 00790343
bourland@bourlandlaw.com
ANNA EBY
State Bar No. 24059707
eby@bourlandlaw.com
ii
CERTIFICATE OF CONFERENCE
I hereby certify that, on December 29, 2014, I conferred with counsel for
Appellee via electronic mail regarding this motion. Appellee does not oppose the
granting of this motion for leave.
/s/ Anna Eby______________
Anna Eby
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of this document was served via
electronic service on this the 29th day of December, 2014 on the following:
Jessica Lobes
Dickman Law Offices, PLLC
6440 N. Central Expressway, Suite 200
Dallas, Texas 75206
/s/ Anna Eby______________
Anna Eby
iii
ACCEPTED
03-14-00016-CV
3583373
THIRD COURT OF APPEALS
AUSTIN, TEXAS
12/23/2014 3:20:56 PM
JEFFREY D. KYLE
CLERK