ACCEPTED
01-15-00435-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
10/16/2015 6:31:36 PM
CHRISTOPHER PRINE
CLERK
NO. 01-15-435-CV
FILED IN
1st COURT OF APPEALS
IN THE COURT OF APPEALS HOUSTON, TEXAS
10/16/2015 6:31:36 PM
FIRST DISTRICT OF TEXAS, HOUSTON
CHRISTOPHER A. PRINE
Clerk
IRVING DROBNY, as representative of NAIU and NAIC,
Appellant
v.
AMERICAN NATIONAL INSURANCE COMPANY,
Appellee
APPELLEE’S BRIEF
Janet L. Rushing
State Bar No. 17403100
Roni S. Mihaly
State Bar No. 24027899
David J. Booth
State Bar No. 24034333
Greer, Herz & Adams, L.L.P.
2525 South Shore Blvd., Suite 203
League City, Texas 77539
(409) 797-3204 (Phone)
(281) 538-3791 (Fax)
ORAL ARGUMENT REQUESTED
CERTIFICATE OF COMPLIANCE
Pursuant to Texas Rule of Appellate Procedure 9.4, I certify that there are
6,930 words in this document, excepting those portions of the brief listed in Rule
9.4(i)(1), as calculated by the word count feature of Microsoft Word 2010, which
was used to prepare this document.
/s/ Roni S. Mihaly
Roni S. Mihaly
CERTIFICATE OF SERVICE
This is to certify that on the 16th day of October, 2015, a copy of the
foregoing document was served pursuant to the Texas Rule of Appellate Procedure
9.5 upon the following counsel:
Via E-File and Commerical Delivery Service
Ms. Savannah Robinson
Law Offices of Savannah Robinson
1822 Main
Danbury, Texas 77534
/s/ Roni S. Mihaly
Roni S. Mihaly
34