Paul Stamatis, Jr., as Independent of the Estate of Paul Stamatis v. Methodist Willbrook Hospital, the Methodist Health Care System, Daniel Mao, M.D., and Neptune Emergency Services, P.A.

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ACCEPTED 14-14-00492-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 5/12/2015 4:42:07 PM CHRISTOPHER PRINE CLERK IN THE FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS FILED IN ______________ 14th COURT OF APPEALS HOUSTON, TEXAS 5/12/2015 4:42:07 PM NO. 14-14-00492-CV CHRISTOPHER A. PRINE ______________ Clerk PAUL STAMATIS, JR., AS INDEPENDENT EXECUTOR OF THE ESTATE OF PAUL STAMATIS, DECEASED, Appellant V. METHODIST WILLOWBROOK HOSPITAL, DANIEL MAO, M.D., AND NEPTUNE EMERGENCY SERVICES, P.A., Appellees On Appeal from the 190th District Court Harris County, Texas Trial Court Cause No. 2010-34910 APPELLANT’S MOTION FOR LEAVE TO FILE ITS REBUTTAL TO APPELLEE’S POST-SUBMISSION BRIEF Respectfully submitted, THE LEWIS LAW FIRM /s/ J. Craig Lewis J. Craig Lewis State Bar No. 12283500 2905 Sackett Street. Houston, Texas 77098 Telephone: 713.238.7715 Facsimile: 713.238.7888 Email: jenniferb@LLF7.com ATTORNEYS FOR APPELLANT TO THE HONORABLE COURT OF APPEALS: Appellant, Paul Stamatis, Jr. files this Motion for Leave to File its Post- Submission Rebuttal to Appellee’s Post-Submission Brief. Appellant seeks leave to file its Post-Submission Rebuttal submitted concurrently herewith to respond to the Post-Submission Brief filed by the Appellees on May 7, 2015. The Appellees sought leave from this Court to file their Post- Submission Brief because at oral argument on April 30, 2015, they did not have adequate enough time to respond to questions posed by the Justices of the Panel. Had the Appellees responded to the Justices of the Panel at oral argument, Appellant would have rebutted the Appellees on the manner set forth in this Rebuttal. Based on Appellant’s Post-Submission Rebuttal to the Appellees’ Post-Submission Brief, Appellant believes that its Rebuttal will assist the Court in its deliberations PRAYER FOR RELIEF For the reasons set forth above, Appellant requests that this Court grant his Motion for Leave to File Post-Submission Rebuttal, direct the clerk to accept and file Appellant’s Post-Submission Rebuttal, and grant him all other relief to which he may be entitled. [signature page follows] -2- Respectfully submitted, THE LEWIS LAW FIRM /s/ J. Craig Lewis J. Craig Lewis State Bar No. 12283500 2905 Sackett Street Houston, Texas 77098 Telephone: 713.238.7715 Facsimile: 713.238.7888 Email: jenniferb@LLF7.com ATTORNEYS FOR APPELLANT CERTIFICATE OF CONFERENCE As required by Texas Rule of Appellate Procedure 10.1(a)(5), I certify that I have conferred with opposing counsel, listed below, about the merits of this motion with the following results: Oscar De la Rosa, with the DE LA ROSA LAW FIRM, attorney for Appellee, Methodist Willowbrook Hospital, does not oppose motion. LaVerne Chang, with CARDWELL & CHANG, attorney for Appellees, Daniel Mao, M.D. and Neptune Emergency Services, P.A., does not oppose motion. Dated: May 12, 2015 /s/ Craig Lewis J. Craig Lewis -3- CERTIFICATE OF SERVICE This is to certify that on this 12th day of May, 2015 a true and correct copy of the foregoing instrument was served upon opposing counsel via e-serve. I further certify that I have complied with the provisions of Rules 21 and 21a of the Texas Rules of Civil Procedure. Ms. LaVerne Chang Via E-Serve CARDWELL & CHANG 511 Lovett Boulevard Houston, Texas 77006 Counsel for Appellees, Daniel Mao, M.D. and Neptune Emergency Services, P.A. Mr. Oscar De la Rosa Via E-Serve DE LA ROSA LAW FIRM Three Riverway, Suite 1820 Houston, Texas 77056 Counsel for Appellee, Methodist Willowbrook Hospital /s/ J. Craig Lewis J. Craig Lewis ATTORNEY FOR APPELLANT, PAUL STAMATIS, JR., AS INDEPENDENT EXECUTOR OF THE ESTATE OF PAUL STAMATIS, DECEASED -4-