ACCEPTED
04-14-00751-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
6/29/2015 2:03:28 PM
KEITH HOTTLE
NO. 04-14-00751-CV
CLERK
IN THE COURT OF APPEALS
FOURTH DISTRICT OF TEXAS FILED IN
4th COURT OF APPEALS
SAN ANTONIO, TEXAS SAN ANTONIO, TEXAS
06/29/2015 2:03:28 PM
KEITH E. HOTTLE
JOSEFINA ALEXANDER GONZALEZ, ET AL, Clerk
Appellants
v.
RAYMOND S. DE LEON II, ET AL,
Appellee
APPELLANTS’ MOTION FOR LEAVE TO FILE
POSTSUBMISSION BRIEF
TO THE HONORABLE FOURTH COURT OF APPEALS:
At oral argument this Court raised several questions, the responses to
which Appellants believe merit more discussion. Therefore, Appellants
submit this post-submission brief in an effort to more fully address the
matters on which this Court expressed interest.
For these reasons, Appellants ask this Court to grant them leave to file
their Post-Submission Brief, which they are submitting simultaneously with
this motion.
Respectfully submitted,
/s/Robinson C. Ramsey______
ROBINSON C. RAMSEY
State Bar No. 16523700
Email: rramsey@langleybanack.com
LANGLEY & BANACK, INC.
Appellants’ Motion for Leave to File Post-Submission Brief Page 1
Trinity Plaza II, Suite 900
745 E. Mulberry Avenue
San Antonio, Texas 78212
Telephone: 210.736.6600
Telecopier: 210.735.6889
ATTORNEY FOR APPELLANTS
CERTIFICATE OF CONFERENCE
Appellants’ attorney has conferred with counsel for Appellee
Raymond S. De Leon II by email, but has not received a response.
/s/ Robinson C. Ramsey
ROBINSON C. RAMSEY
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the above and foregoing
document has been served on this 29th day of June, 2015, to the following
counsel of record:
Judith R. Blakeway
Email: Judith.blakeway@strasburger.com
James Maverick McNeel
Email: james.mcneel@strasburger.com
Laura C. Mason
Email: laura.mason@strasburger.com
STRASBURGER & PRICE, LLP
2301 Broadway
San Antonio, Texas 78215
Attorneys for Raymond S. De Leon II, Trustee of the Family Trust
/s/Robinson C. Ramsey______
ROBINSON C. RAMSEY
Appellants’ Motion for Leave to File Post-Submission Brief Page 2