ACCEPTED
04-15-00623-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
10/30/2015 5:43:53 PM
KEITH HOTTLE
CLERK
FILED IN
4th COURT OF APPEALS
October 30, 2015 SAN ANTONIO, TEXAS
10/30/2015 5:43:53 PM
KEITH E. HOTTLE
Clerk
JUDITH R. BLAKEWAY
210.250.6001
judith.blakeway@strasburger.com
REQUEST FOR DOCUMENTS TO BE INCLUDED
IN SUPPLEMENTAL CLERK'S RECORD
TO: Ms. Teresa Guerra
Court Clerk, Probate Court No.2
100 Dolorosa, Room 117
San Antonio, Texas 78205
FR: Judith R. Blakeway
Attorney for Appellant, Pamela Ann Childs McCaskill
RE: Defendant's request for documents to be included in the clerk's record for Cause No.
20 14-PC-0056; In the Estate of Marjorie A. Childs, Deceased, in the Probate Court No.2
of Bexar County, Texas
On October 2, 2015, Defendants filed a request for documents to be included in the
Clerk's Record. Among the documents requested was Defendant Pamela Ann Child McCaskill's
Response to Plaintiff's Cross Motion for Partial Summary Judgment and No Evidence Motion
for Partial Summary Judgment, filed on September 11, 2015. Attached and e-filed with the
response were the following exhibits which were not included in the Clerk's record filed with the
Court:
1. All deposition exhibits (Nos. 27-60) to Exhibit B (Transcript of July 29, 2015 deposition
of Mollie Allen Childs). (Exhibits are linked to that transcript and can be easily accessed
either by clicking on the highlighted exhibit numbers at page 4 of the transcript, or by
clicking on the paper clip icon for attachments to the left of the screen).
2. Remaining Parts 4 - 14 of Pamela McCaskill's response to Motion for Summary
Judgment, which include the final portion of Exhibit E, as well as Exhibits F-L. (These
missing chunks are designated separately on the court's docket as Parts 4-14 of Pamela
McCaskill's response):
Exhibit E: Transcript of June 26,2015 deposition of Mike Donelson (beginning at Filing
Part 4, marked p. 203);
Strasburger & Price, LLP
2;GUlcBl·.dJ.lidwe.¥D9¥IOSlittrMifunio,Texas 78215- 1157 I 210.250.6000 tel I 210.250.6100 fax I www.strasburger.com
Austin I Collin County I Dallas I Houston I San Antonio I New York I Washington, D.C. I MexicoCity-Strasburger&Price,SC
Ms. Teresa Guerra
Court Clerk Probate Court No.2
October 30, 2015
Page 2
Exhibit F: Transcript of June 26, 2015 deposition of James Randy Beck, with Exhibits
1-5;
Exhibit G: Transcript of June 16, 2012 recorded conversation between Pamela
McCaskill and Marjorie A. Childs;
Exhibit H: Documents produced by CPA Mike Donelson which were previously
withheld as privileged;
Exhibit I: 1993 Trust Agreement;
Exhibit J: Plaintiffs original and amended responses to Defendant Pamela McCaskill's
Request for Production;
Exhibit K: Plaintiffs First Amended Petition and Answer to Counterclaims of Susan
Kaye Addison and Pamela Ann Childs McCaskill;
Exhibit L: Transcript of the August 20, 2015 deposition of Frances Perkins, with
exhibits 1-5.
I am requesting that the Clerk's Record be supplemented with these exhibits.
By copy of this letter, I am notifying all counsel of record of this request, as well as the
Court of Appeals.
Respectfully submitted,
STRASBURGER & PRICE, LLP
By: /s/ Judith R. Blakewav
JUDITH R. BLAKEWAY
State Bar No. 02434400
judith.blakeway@strasburger.com
2301 Broadway
San Antonio, Texas 78215
Telephone: (210) 250-6000
Facsimile: (210) 250-6100
ATTORNEYS FOR APPELLANT
PAMELA ANN CHILDS McCASKILL
I 98D643. IISPSNJ409210102/J03DI 5
Ms. Teresa Guerra
Court Clerk Probate Court No.2
October 30, 2015
Page 3
CERTIFICATE OF SERVICE
I hereby certify that on the 30th day of October, 2015, a true and correct copy of the
above and foregoing Request for Documents to be Included in the Clerk's Record has been
transmitted in accordance with the requirement of the Texas Rules of Civil Procedure, addressed
as follows:
Rudy A. Garza Ben A. Wallis, III
rugar@hfgtx.com Ben A. Wallis Law PC
Charles M. Hornberger 8200IH 10 West #101
boxy@,hfgtx.com San Antonio, Texas 78230
David Jed Williams baw3@,wallislawsa.com
j wi IIiams(@,hfgtx.com
Stephanie L. Curette Attorneys for Defendant
scurette(@,hfgtx.com Susan Kaye Childs Addison
Hornberger Sheehan Fuller & Garza, Inc.
The Quarry Heights Building
7373 Broadway, Suite 300
San Antonio, Texas 78209
Telephone: (210) 271-1700
Facsimile: (210) 271-1730
Attorneys for Plaintiff Mollie Allen Childs
lsi Judith R. Blakewav
Judith R. Blakeway
I980643.1/SPSAJ3409210 102il 030 15
in the Estate of Marjorie A. Childs
Combined Opinion