Josefina Alexander Gonzalez v. Raymond De Leon ( 2015 )

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