ACCEPTED
04-15-00259-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
6/24/2015 10:14:34 PM
KEITH HOTTLE
CLERK
NO. 04-15-00259-CV
FILED IN
IN THE COURT OF APPEALS 4th COURT OF APPEALS
SAN ANTONIO, TEXAS
FOURTH COURT OF APPEALS DISTRICT OF TEXAS
06/24/2015 10:14:34 PM
SAN ANTONIO, TEXAS
KEITH E. HOTTLE
CITY OF SAN ANTONIO Clerk
APPELLANT
V.
ROXANA TENORIO, INDIVIDUALLY
AND ON BEHALF OF PEDRO TENORIO, DECEASED
APPELLEE
From the 73rd District Court of Bexar County, Texas
Trial Court No. 2014-CI-14704
Honorable Stephani Walsh, Judge Presiding
BRIEF OF APPELLANT,
CITY OF SAN ANTONIO
Dan Pozza Martha G. Sepeda, Acting City Attorney
State Bar No. 16224800 State Bar No. 13143100
Attorney at Law Michael D. Siemer, Assistant City Attorney
239 East Commerce Street State Bar No. 18343670
San Antonio, Texas 78205 Office of the City Attorney
(210) 226-8888 – Phone Litigation Division
(210) 224-6373 – Fax 111 Soledad Street, 10th Floor
danpozza@yahoo.com San Antonio, Texas 78205
(210) 207-8784 – Phone
(210) 207-4357 – Fax
martha.sepeda@sanantonio.gov
michael.seimer@sanantonio.gov
ATTORNEYS FOR APPELLANT,
CITY OF SAN ANTONIO
IDENTITY OF PARTIES AND COUNSEL
Appellant Appellate Counsel
City of San Antonio Dan Pozza
State Bar No. 16224800
Attorney at Law
239 East Commerce Street
San Antonio, TX 78205
(210) 226-8888 – Phone
(210) 224-6373 – Fax
danpozza@yahoo.com
Appellate and Trial Counsel
Martha G. Sepeda, Acting City Attorney
State Bar No. 13143100
Michael D. Siemer, Assistant City Attorney
State Bar No. 18343670
Office of the City Attorney
Litigation Division
111 Soledad Street, 10th Floor
San Antonio, TX 78205
(210) 207-8784 – Phone
(210) 207-4357 – Fax
martha.sepeda@sanantonio.gov
michael.seimer@sanantonio.gov
Appellee Appellate and Trial Counsel
Rosana Tenorio, Individually and Joe Brad Brock
on Behalf of Pedro Tenorio, State Bar No. 03040830
Deceased Law Office of Joe Brad Brock
5866 S. Staples, Suite 103
Corpus Christi, TX 78413
(361) 884-1086 – Phone
(361) 884-8446 – Fax
joebrad@thebrocklawfirm.com
-ii-
TABLE OF CONTENTS
Page
IDENTITY OF PARTIES AND COUNSEL ........................................................... ii
TABLE OF CONTENTS ......................................................................................... iii
INDEX OF AUTHORITIES......................................................................................v
STATEMENT OF THE CASE ............................................................................... vii
STATEMENT REGARDING ORAL ARGUMENT ........................................... viii
ISSUES PRESENTED............................................................................................. ix
1. Because the evidence is conclusive that the City of San Antonio did
not have subjective awareness of its fault, the City of San Antonio did
not have actual notice. ................................................................................... ix
2. Because the City of San Antonio conclusively disproved it had actual
notice, it retains governmental immunity from suit that defeats the
trial court’s subject matter jurisdiction. ......................................................... ix
STATEMENT OF FACTS ........................................................................................1
SUMMARY OF THE ARGUMENT ........................................................................2
ARGUMENT .............................................................................................................3
I. Notice provisions are jurisdictional requirements in suits against a
governmental unit. .......................................................................................... 3
II. Tenorio did not comply with any of the notice provisions............................. 5
III. Actual notice means subjective awareness of fault. ....................................... 5
IV. There is not a shred of evidence within the exhaustive investigative
materials provided to Tenorio that the City had subjective awareness
of fault. ............................................................................................................ 9
CONCLUSION ........................................................................................................10
-iii-
PRAYER ..................................................................................................................11
CERTIFICATE OF SERVICE ................................................................................12
CERTIFICATE OF COMPLIANCE .......................................................................13
APPENDIX
Tab A Order Denying Defendant, City of San Antonio’s Plea to the
Jurisdiction
-iv-
INDEX OF AUTHORITIES
Cases Page
Bland Indep. Sch. Dist. v. Blue,
34 S.W.3d 547 (Tex. 2000) ........................................................................3
Cathey v. Booth,
900 S.W.2d 339 (Tex. 1995) (per curiam) ............................................ 5, 6
City of Amarillo v. Martin,
971 S.W.2d 426 (Tex. 1998) ......................................................................4
City of Dallas v. Carbajal,
324 S.W.3d 537 (Tex. 2010) ................................................................. 4, 7
City of Houston v. Torres,
621 S.W.2d 588 (Tex. 1981) ......................................................................5
Harris County v. Sykes,
136 S.W.3d 635 (Tex. 2004) ......................................................................4
Mayhew v. Town of Sunnyvale,
964 S.W.2d 922 (Tex. 1998) ......................................................................3
Miranda v. Tex. Dep’t of Parks & Wildlife,
133 S.W.3d 217 (Tex. 2004). .....................................................................3
Tex. Ass’n of Bus. v. Tex. Air Control Bd.,
852 S.W.2d 440 (Tex. 1993) ......................................................................3
Tex. Dep’t of Criminal Justice v. Miller,
51 S.W.3d 583 (Tex. 2001) ................................................................... 3, 4
Tex. Dep’t of Transp. v. Jones,
8 S.W.3d 636 (Tex. 1999) ..........................................................................4
Tex. Natural Res. Conservation Comm’n v. IT-Davy,
74 S.W.3d 849 (Tex. 2002) ........................................................................3
Texas Department of Criminal Justice v. Simons,
140 S.W.3d 338 (Tex. 2004) ................................................................. 6, 8
-v-
Statutes
TEX. CIV. PRAC. & REM. CODE ANN., Chapter 101.......................... 1, 2, 4, 5, 8, 9
TEX. GOV’T CODE § 311.034.................................................................................4
-vi-
STATEMENT OF THE CASE
Nature of the case. Roxana Tenorio, Individually and on behalf of Pedro
Tenorio, Deceased (“Tenorio”), brought suit against the
City of San Antonio under the Texas Tort Claims Act.
CR 1-6.
Course of proceedings. The City of San Antonio filed a Plea to the Jurisdiction
based on Tenorio’s failure to provide notice of her
claim within the relevant city charter and statutory
notice provision deadlines and because the City of San
Antonio did not have actual notice of her claim. CR 11-
61.
Trial court disposition. The trial court denied the City of San Antonio’s Plea to
the Jurisdiction. Tab A. CR 76-77.
-vii-
STATEMENT REGARDING ORAL ARGUMENT
Because the evidence is conclusive that the City of San Antonio was not
subjectively aware of its fault, the City of San Antonio did not have actual notice.
The City of San Antonio does not believe this Court’s decisional process will be
aided by oral argument.
-viii-
ISSUES PRESENTED
1. Because the evidence is conclusive that the City of San Antonio did not have
subjective awareness of its fault, the City of San Antonio did not have actual
notice.
2. Because the City of San Antonio conclusively disproved it had actual notice,
it retains governmental immunity from suit that defeats the trial court’s
subject matter jurisdiction.
-ix-
TO THE HONORABLE FOURTH COURT OF APPEALS:
Appellant, CITY OF SAN ANTONIO, files this its Brief of Appellant, and
respectfully shows the Court as follows:
STATEMENT OF FACTS
Tenorio brought suit against the City of San Antonio (“the City”) under the
Texas Tort Claims Act (“TTCA”) TEX. CIV. PRAC. & REM. CODE ANN., Chapter
101, alleging that she was severely injured, and her husband was killed, in a motor
vehicle collision on September 2, 2012. At the time of the collision she and her
husband were riding on a motorcycle on Loop 410 in San Antonio, Texas when
they were struck head-on by a vehicle being operated by Defendant, Benito Garza.
Garza was driving on the wrong side of the highway at the time of the collision.
Tenorio alleges that at the time of the collision Garza was being pursued by
officers of the San Antonio Police Department (“SAPD”) and further alleges that
SAPD officers were negligent in initiating the pursuit and in failing to terminate
the pursuit. CR 1-6.
Tenorio did not give the City notice of her claim, nor of the claim asserted
on behalf of her husband, before filing suit almost two years after the collision.
Tenorio failed to give the City notice of her claim within ninety (90) days as
required under Article XII, Sec. 150 of the City of San Antonio Charter (CR 58)
and failed to give notice of her claim within six months as required by §101.101
Tex. Civ. Prac. & Rem. Code Ann. Instead, Tenorio asserts that the City had actual
notice of her claim as a result of (1) the “Texas Peace Officer’s Crash Report”
(TXDOT Form CR-3) prepared by SAPD after the accident 1 (2) a number written
witness statements; and (3) by the SAPD Incident Report. CR 55.
SUMMARY OF THE ARGUMENT
Notice to a governmental entity, such as the City of San Antonio, is a
jurisdictional requirement. Tenorio did not give notice of her claim to the City of
San Antonio as required by TEX. CIV. PRAC & REM. CODE ANN. §101.101(a) nor
did she give notice of her claim against the City as required by Article XII, Sec.
150 of the Charter of the City of San Antonio and as ratified by TEX. CIV. PRAC &
REM. CODE ANN. §101.101(b). Likewise, the City of San Antonio did not have
actual, subjective awareness of its alleged fault in producing or contributing to
Tenorio’s injuries or those of her husband. Accordingly, the trial court lacks
subject matter jurisdiction because the City of San Antonio retains its
governmental immunity. Tenorio’s suit should be dismissed for lack of
jurisdiction.
1
The codes contained in the Texas Peace Officer’s Crash Report – Code Sheet (TxDOT
Form CR – 3CS) can be found on the Texas Department of Transportation’s website at:
http://ftp.dot.state.tx.us/pub/txdot-info/trf/crash_notifications/cr3_code_sheet.pdf; also
see CR 59-60.
-2-
ARGUMENT
I. Notice provisions are jurisdictional requirements in suits against a
governmental unit.
Governmental immunity from suit defeats a trial court's subject matter
jurisdiction and is properly asserted in a plea to the jurisdiction. See Miranda v.
Tex. Dep’t of Parks & Wildlife, 133 S.W.3d 217, 224 (Tex. 2004). A plea to the
jurisdiction is a dilatory plea by which a party challenges a court's authority to
determine the subject matter of the action. Bland Indep. Sch. Dist. v. Blue, 34
S.W.3d 547, 554 (Tex. 2000). A party suing a governmental entity bears the
burden of affirmatively showing that the trial court has jurisdiction to hear the
cause. Tex. Dep’t of Criminal Justice v. Miller, 51 S.W.3d 583, 587 (Tex. 2001).
Whether a trial court has subject matter jurisdiction is a question of law subject to
de novo review by the appellate court. Tex. Natural Res. Conservation Comm’n v.
IT-Davy, 74 S.W.3d 849, 855 (Tex. 2002); Mayhew v. Town of Sunnyvale, 964
S.W.2d 922, 928 (Tex. 1998). When considering a plea to the jurisdiction, the
court must construe the pleadings in favor of the pleader and look to the pleader's
intent. Tex. Ass’n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 446 (Tex.
1993). However, the court is not required to look solely to the pleadings when
deciding a plea to the jurisdiction; the court may consider evidence relevant to
jurisdiction when necessary to resolve the jurisdictional issue. Blue, 34 S.W.3d at
555.
-3-
Sovereign immunity from suit defeats a trial court's subject matter
jurisdiction unless the State expressly consents to the suit. Tex. Dep’t of Transp. v.
Jones, 8 S.W.3d 636, 638 (Tex. 1999). Governmental immunity operates like
sovereign immunity to afford similar protection to subdivisions of the State,
including counties, cities, and school districts. Harris County v. Sykes, 136 S.W.3d
635, 638 (Tex. 2004). A plaintiff must affirmatively demonstrate the trial court's
jurisdiction by alleging a valid waiver of immunity. Miller, 51 S.W.3d at 587.
Thus, under the doctrine of governmental immunity, a municipality is immune
from tort liability for its own acts or the acts of its agents and employees unless the
Texas Tort Claims Act, TEX. CIV. PRAC. & REM. CODE ANN. §101.001 et seq. (“the
TTCA”) clearly and unambiguously waives immunity. City of Amarillo v. Martin,
971 S.W.2d 426 (Tex. 1998). In order to recover against a governmental entity,
such as the City of San Antonio, a plaintiff must give timely notice of her claim to
the City. TEX. CIV. PROC. & REM. CODE § 101.101(a).
The provision of notice is a jurisdictional requirement in all suits against a
governmental unit. TEX. GOV’T CODE § 311.034; See also City of Dallas v.
Carbajal, 324 S.W.3d 537 (Tex. 2010). Article XII, Section 150 of the City of San
Antonio Charter requires a plaintiff to give the City written notice of any claim for
injuries or damages within ninety (90) days after the injuries or damages were
sustained, as a condition precedent to recovery. CR 58. Section 101.101(b) of the
-4-
Texas Tort Claims Act (“TTCA”) ratifies and approves this provision. See TEX.
CIV. PRAC & REM. CODE ANN. §101.101(b). The Texas Supreme Court has held
that Charter notice requirements are mandatory and their satisfaction is a condition
precedent to maintaining a cause of action. See City of Houston v. Torres, 621
S.W.2d 588, 591 (Tex. 1981).
II. Tenorio did not comply with any of the notice provisions.
Tenorio concedes in her Answers to Interrogatories that she did not give
notice of her claim to the City of San Antonio within the time prescribed by the
City Charter. She likewise concedes that she did not give notice of her claim
against the City of San Antonio in the timeframe provided by Tex. Civ. Prac. &
Rem. Code Ann. §101.101(a). CR 55. Therefore, Tenorio must rely upon the
“actual notice” provision of the TTCA.
III. Actual notice means subjective awareness of fault.
Section 101.101(c) of the TTCA provides that the formal notice
requirements of section 101.101(a) “do not apply if the governmental unit has
actual notice that death has occurred, that the claimant has received some injury, or
that the claimant's property has been damaged.” TEX. CIV. PRAC & REM. CODE
ANN. § 101.101(c). In Cathey v. Booth, the Texas Supreme Court held that a
governmental entity has actual notice when it has “knowledge of (1) a death,
injury, or property damage; (2) the governmental unit's alleged fault producing or
-5-
contributing to the death, injury, or property damage; and (3) the identity of the
parties involved.” Cathey v. Booth, 900 S.W.2d 339, 341 (Tex. 1995) (per curiam).
In Texas Department of Criminal Justice v. Simons, 140 S.W.3d 338, 343–48 (Tex.
2004) the Texas Supreme Court clarified the meaning of the second requirement:
What we intended in Cathey by the second requirement
... was that a governmental unit have knowledge that
amounts to the same notice to which it is entitled by
section 101.101(a). That includes subjective awareness of
its fault, as ultimately alleged by the claimant, in
producing or contributing to the claimed injury.... It is not
enough that a governmental unit should have investigated
an incident ..., or that it did investigate, perhaps as part of
routine safety procedures, or that it should have known
from the investigation it conducted that it might have
been at fault. If a governmental unit is not subjectively
aware of its fault, it does not have the same incentive to
gather information that the statute is designed to provide,
even when it would not be unreasonable to believe that
the governmental unit was at fault.
140 S.W.3d at 347–48.
In this passage, and several others, the Texas Supreme Court has made clear
that merely investigating an accident is insufficient to provide a city with actual
notice of a claim. See, e.g., id. at 347 (“Cathey cannot fairly be read to suggest that
a governmental unit has actual notice of a claim if it could or even should have
learned of its possible fault by investigating the incident.”); id. at 348 (“[A]
governmental unit cannot acquire actual notice merely by conducting an
investigation, or even by obtaining information that would reasonably suggest its
-6-
culpability. The governmental unit must have actual, subjective awareness of its
fault in the matter.”).
The Texas Supreme Court has explicitly held that a police report noting the
perceived cause of an accident does not provide a governmental unit with actual
notice of its fault in causing the accident. In City of Dallas v.
Carbajal, 324 S.W.3d 537 (Tex. 2010) the Texas Supreme Court held that a police
report concerning an automobile accident was, at most, an initial response to an
accident, and held that the police report failed to give the City of Dallas actual
notice of the Plaintiff’s claim. See id. at 538.
The facts of Carbajal are highly instructive. Olivia Carbajal sued the City
of Dallas for injuries she sustained after driving onto an excavated road. Id. at 538.
A Dallas police officer who responded to the accident filed a written report
describing the accident, in relevant part, as follows:
Comp[lainant] said that she saw the barricades but none
were blocking what she thought was a clear way to get on
the freeway. Comp[lainant] said that before she knew it
she had driven her veh[icle] into a gap on the street. [I]
observed at the listed offense loc[ation] that there were
no barricades blocking the gap in the road.
Id. at 538.
Summarizing the incident, the police report stated that Carbajal drove her
“veh[icle] into [a] gap in [the] street [that] was not properly blocked.” Id. at 538.
Approximately a year after the accident, Carbajal filed suit against the City of
-7-
Dallas. Id. at 538. It was undisputed that Carbajal did not provide formal notice as
required by TEX. CIV. PRAC & REM. CODE ANN. § 101.101(a). Id. at 538. Carbajal
contended, however, that the police report provided the City of Dallas with
subjective awareness of the claim, thereby establishing actual notice under TEX.
CIV. PRAC & REM. CODE ANN. § 101.101(c). Arguing that the report did not
provide actual notice, the City of Dallas filed a plea to the jurisdiction. The trial
court denied the plea, and the court of appeals affirmed.
In reversing the holding of the Dallas Court of Appeals, the Texas Supreme
Court noted that, even though both parties agreed that the road was not properly
barricaded, the police report in question did not provide the City of Dallas with
subjective awareness of its fault because it did not expressly state that the City was
at fault. Carbajal, 324 S.W.3d at 538. The Court noted that the report only
described the apparent cause of the accident (missing barricades) and did not say
who failed to erect or maintain the barricades. Id. at 538. The Texas Supreme
Court held that the police report was merely a routine investigation, and was
insufficient to provide actual notice to the City of Dallas. Id. at 538 (citing Texas
Department of Criminal Justice v. Simons, 140 S.W.3d 338 (Tex. 2004)).
-8-
IV. There is not a shred of evidence within the exhaustive investigative
materials provided to Tenorio that the City had subjective awareness of
fault.
In this case, Tenorio admits that she failed to give notice of her claim to the
City of San Antonio as required by §101.101 Tex. Civ. Prac. & Rem. Code Ann.
Likewise, Tenorio admits that she did not give notice to the City of San Antonio as
required by the City Charter. Instead, Tenorio contends (CR 55) that the City had
actual notice of her claim by virtue of (1) the Texas Peace Officer’s Crash Report
(CR 22-25); (2) the sworn statements of the witnesses (CR 26-43); and (3) the
SAPD Offense Report concerning the crash in question (CR 44-52).
But none of these documents support Tenorio’s contention. Nowhere in any
of the documents identified by Tenorio does it allege that the City, or any
employee of the City, caused the accident, was at fault, did anything wrong or was
in any way culpable. In Box No. 36 of the Texas Peace Officer’s Crash Report,
labeled “Contributing Factors (Investigator’s Opinion)”, the vehicle designated as
“Unit 1” ( Unit 1 is identified on the first page of the Crash Report as being
operated by Garza) the investigating officer listed the code number “43” which
means “Fleeing or Evading Police”. CR 23. The investigating officer did not list
any other factors that contributed to the accident. The investigating officer only
attributed contributing factor to Garza and did not list any city employee as
contributing to the cause of the accident.
-9-
In the “Investigator’s Narrative Opinion of What Happened” the
investigating officer notes that “driver of unit 1 was evading police” but says
nothing that even infers that any City employee did anything wrong or was at fault
in any way in causing the accident. CR 23. Nowhere in any of the written
statements identified by the Tenorio does anyone say that the City, or any of its
employees did anything wrong, and nowhere in the SAPD Incident report does it
say that the City, or any of its employees did anything wrong. CR 26-52. Absent
some evidence, somewhere, that the City or its employees did something wrong or
was in some way at fault in causing the Tenorio’s injuries or her husband’s death,
there is no actual notice to the City. If there is no actual notice to the City, then the
City’s immunity to suit is preserved and the case must be dismissed for lack of
subject matter jurisdiction.
CONCLUSION
Notice of a claim to a governmental entity, such as the City of San Antonio,
is a jurisdictional requirement. Because Tenorio did not give formal notice of her
claim to the City of San Antonio under the City Charter or by statute, she must
show that the City had actual, subjective awareness of its fault or culpability in
causing the accident. In this case, the City did not have actual notice of its alleged
culpability. The Texas Peace Officer’s Crash Report, the written witness
statements and the SAPD Offense Report concerning the crash in question do not
-10-
contain any allegation of wrongdoing on the part of the City or its officers. None of
the documents submitted as part of the City’s Plea or Tenorio’s response make any
reference to the City’s fault or culpability in causing the accident. The City
conclusively proved it did not have actual notice.
PRAYER
Appellant, City of San Antonio, prays that the trial court’s denial of its Plea
to the Jurisdiction be reversed and the case dismissed for lack of subject-matter
jurisdiction. The City also prays for all such other relief to which it is entitled.
Respectfully submitted,
Martha G. Sepeda, Acting City Attorney
State Bar No. 13143100
Michael D. Siemer, Assistant City Attorney
State Bar No. 18343670
Office of the City Attorney
Litigation Division
111 Soledad Street, 10th Floor
San Antonio, Texas 78205
(210) 207-8784 – Phone
(210) 207-4357 – Fax
martha.sepeda@sanantonio.gov
michael.seimer@sanantonio.gov
-11-
/s/Dan Pozza
Dan Pozza
State Bar No. 16224800
239 East Commerce Street
San Antonio, Texas 78205
(210) 226-8888 – Phone
(210) 224-6373 – Fax
danpozza@yahoo.com
ATTORNEYS FOR APPELLANT
CITY OF SAN ANTONIO
CERTIFICATE OF SERVICE
I hereby certify that a true copy of the above and foregoing Brief of
Appellant was served via electronic transmission, on this the 25th day of June,
2015, to:
Joe Brad Brock
Law Office of Joe Brad Brock
5866 S. Staples, Suite 103
Corpus Christi, TX 78413
joebrad@thebrocklawfirm.com
Attorney for Rosana Tenorio, Individually
and on Behalf of Pedro Tenorio, Deceased
/s/Dan Pozza
-12-
CERTIFICATE OF COMPLIANCE
1. The undersigned certifies that this Brief of Appellant complies with the type-
volume limitation of Tex. R. App. P. 9.4(i)(2)(D) because this brief contains
2,600 words, excluding parts of the brief exempted by Tex. R. App. P.
9.4(i)(1).
2. This brief complies with the typeface requirement of Tex. R. App. P. 9.4(e)
because this brief has been prepared in a conventional typeface of 14-point
font in the text.
/s/Dan Pozza
-13-
TAB A
No. 2014CI14704
ROXANA TENORIO, INDIVIDUALLY § IN THE DISTRICT COURT
AND ON BEHALF OF PEDRO
TENORIO, DECEASED
§
v. § 73RD JUDICIAL DISTRICT
§
BENITO GARZA AND CITY OF SAN §
ANTONIO § BEXAR COUNTY, TEXAS
ORDER DENYING DEFENDANT, CITY OF SAN ANTONIO'S
PLEA TO THE JURISDICTION
On this date came on to be heard Defendant CITY OF SAN ANTONIO'S Plea to
the Jurisdiction. The Plaintiff and the Defendant appeared by and through counsel, and
after considering the City of San Antonio's Plea to the Jurisdiction, the pleadings on file
and the argument of counsel, the Court finds the Defendant, City of San Antonio's Plea
to the Jurisdiction should be in all things DENIED.
Accordingly, it is Ordered, Adjudged, and Decreed that Defendant, City of San
Antonio's, Plea to the Jurisdiction is DENIED.
11PfJ../1...
SIGNED AND ENTERED this l0 day ofMttrch, 2015.
APPROVED AS TO FORM ONLY:
CITY OF SAN ANTONIO
Martha G. Sepeda, Acting City Attorney
SBN: 13143100
Office of the City Attorney
Litigation Division
111 Soled St., 10111 Floor
San Ant ·o, TX 78205
1emer
Assistant City Attorney
SBN: 18343670
(210) 207-8784 I (210) 207-4357 FAX
Attorney for Defendant, City of San Antonio
Law Offi e o~oe, Bra 'Brock
5866 S. S pl , S ite 103
Corpus Ch ti , a 78413
\
Joe Brad B o ~.
Attorney for laintiff
SBN: