Bexar County Civil Service Commission v. Carmella Guerrero

Opinion

ACCEPTED

04-15-00341-cv

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

12/8/2015 2:57:17 PM

KEITH HOTTLE

CLERK

NO. 04-15-00341-CV

IN THE COURT OF APPEALS FILED IN 4th COURT OF APPEALS

FOURTH JUDICIAL DISTRICT SAN ANTONIO, TEXAS SAN ANTONIO, TEXAS 12/8/2015 2:57:17 PM

______________________________________________________

KEITH E. HOTTLE

Clerk

BEXAR COUNTY CIVIL SERVICE COMMISSION

Appellants

vs.

CARMELLA GUERRERO

Appellee

___________________________________________________

APPELLEE’S UNOPPOSED MOTION FOR LEAVE TO FILE AMENDED APPELLEE’S BRIEF

TO THE HONORABLE COURT OF APPEALS:

Comes now Appellee, Carmella Guerrero and pursuant to TEX. R. APP. P.

38.7 and moves this Court to grant her leave to file her Amended Appellee’s Brief to correct clerical errors contained in the brief.

I.

Appellee Carmella Guerrero timely filed her Appellee’s Brief on December 4, 2015. After reviewing Appellee’s Brief on December 7, 2015, counsel for Appellee discovered a few clerical errors in the brief. In the interest of justice and to ensure the brief is understood by this Court and the parties, Appellee hereby

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requests that this Court grant her leave to file her Amended Appellee’s Brief, which corrects the clerical errors. See TEX. R. APP. P. 38.7. The Amended Appellee’s Brief is filed as an exhibit hereto.

II.

For the above and foregoing reasons, Appellee respectfully requests that this Court grant her leave to file her Amended Appellee’s Brief. The undersigned communicated with Clarkson F. Brown, Attorney for Appellant Bexar County Civil Service Commission, and he indicated Appellant does not oppose this Motion.

WHEREFORE, premises considered, Appellee, Carmella Guerrero, prays that this Court grant her leave to file her Amended Appellee’s Brief. Appellee prays for such other and further relief both in law and in equity to which she may be justly entitled to receive.

Respectfully submitted,

/s/ Robert W. Clore_______ Robert W. Clore

State Bar No. 24012436

15481 South Padre Island Drive Suite 101

Corpus Christi, Texas 78418 Telephone: (361) 558-3527 Facsimile: (361) 949-0908 rclore@robclorelaw.com

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Orlando Lopez

Lopez Scott, L.L.C.

State Bar No. 2401096

3703 N. St. Mary’s Street, Suite 200 San Antonio, Texas 78212

Telephone: (210) 472-2100 Telecopier: (210) 472-2101 olopez@lopezscott.com

ATTORNEYS FOR APPELLEE, CARMELLA GUERRERO

CERTIFICATE OF CONFERENCE I, Robert W. Clore, certify that I communicated with Clarkson F. Brown, Attorney for Appellant, Bexar County Civil Service Commission, and he indicated that Appellant does not oppose this Motion.

/s/ Robert W. Clore_______ ROBERT W. CLORE

CERTIFICATE OF SERVICE

This is to certify that the above and foregoing instrument has been forwarded to counsel as indicated below on this the 8th day of December, 2015.

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Clarkson F. Brown, Attorney for the Bexar County Civil Service Commission, cbrown@bexar.org.

VIA E-FILING

/s/ Robert W. Clore_______ Robert W. Clore