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. ( 2015 )

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]
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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
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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
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