Leticia B. Loya v. Ian Taylor, Jacobus Sterken, Stichting Tinsel Group, Vitol Holding II S.A. and Tinsel Group, S.A. ( 2015 )

ACCEPTED
01-14-01014-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
5/21/2015 10:04:35 AM
CHRISTOPHER PRINE
CLERK
No. 01-14-01014-CV
__________________________________
FILED IN
1st COURT OF APPEALS
IN THE COURT OF APPEALS FOR THE HOUSTON, TEXAS
FIRST DISTRICT OF TEXAS AT HOUSTON 5/21/2015 10:04:35 AM
__________________________________ CHRISTOPHER
Clerk
A. PRINE
LETICIA LOYA,
Appellant,
v.
IAN TAYLOR, JACOBUS STERKEN, STICHTING TINSEL GROUP,
VITOL HOLDING II S.A., AND TINSEL GROUP, S.A.,
Appellees.
__________________________________
UNOPPOSED MOTION FOR LEAVE TO FILE SURREPLY
__________________________________
On Appeal from the 190th District Court, Harris County, Texas
Trial Court Cause No. 2012-33464
__________________________________
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
Appellees Ian Taylor, Jacobus Sterken, Stichting Tinsel Group, Vitol
Holding II, S.A., and Tinsel Group S.A., file this Unopposed Motion for Leave to
File Surreply and would show the Court as follows:
1. Appellant filed her Brief of Appellant on February 13, 2015.
Appellees filed their Brief of Appellees on March 25, 2015. Appellant filed her
Reply Brief on May 4, 2015.
2. This case is not yet set for submission. The filing of this Surreply will
not delay the disposition of this case.
3. Appellee seeks to file a Surreply, attached to this Motion, to briefly
address arguments raised in the Reply relating to specific jurisdiction, the burden
of proof, and the Texas Supreme Court’s case of Kelly v. Gen. Interior Constr.,
Inc., 301 S.W.3d 653, 658–59 (Tex. 2010).
4. This motion is unopposed.
For all the foregoing reasons, Appellees respectfully request this Court to
grant this Unopposed Motion for Leave to File Surreply and grant Appellees such
other and further relief to which they may be justly entitled.
Respectfully submitted,
VINSON & ELKINS L.L.P.
/s/ Patrick W. Mizell
Patrick W. Mizell
Attorney-In-Charge
Texas Bar No. 14233980
Catherine B. Smith
Texas Bar No. 03319970
Deborah C. Milner
Texas Bar No. 24065761
Jaclyn M. Lynch
Texas Bar No. 24083429
1001 Fannin, Suite 2500
Houston, Texas 77002-6760
Telephone: 713.758.2932
Facsimile: 713.615.5912
e-mail: pmizell@velaw.com
e-mail: csmith@velaw.com
e-mail: cmilner@vela.com
e-mail: jaclynlynch@velaw.com
Attorneys for Appellees Ian Taylor, Jacobus Sterken,
Stichting Tinsel Group, Vitol Holding II, S.A., and Tinsel Group, S.A.
CERTIFICATE OF CONFERENCE
I hereby certify that on May 18, 2015, I conferred with Jennifer Job
(attorney for Appellant, Leticia Loya) via email, and she indicated that Appellant
was not opposed to this extension motion, and we have agreed that Appellee is not
opposed to a response to the sur-reply if deemed necessary.
/s/ Patrick W. Mizell
Patrick W. Mizell
CERTIFICATE OF SERVICE
The undersigned certifies that on May 21, 2015, the foregoing Unopposed
Motion for Leave to File Surreply was served electronically on the following
parties in accordance with the requirements of the Texas Rules of Appellate
Procedure:
Jennifer Job
James E. Payne
Provost Umphrey Law Firm, L.L.P.
490 Park Street
P. O. Box 4905
Beaumont, Texas 77701
409.835.8605
jjob@pulf.com
jpayne@pulf.com
Attorneys for Appellant Leticia Loya
/s/ Catherine B. Smith
Catherine B. Smith