William M. Collins and Patricia Collins v. Dr. Oliver Williams

• Court: Court of Appeals of Texas
• Decided: January 16, 2015
• Docket: 04-14-00491-CV
• Status: Published

Opinion

NO. 04-14-0491-CV

TEXAS COURT OF APPEALS FOURTH DISTRICT SAN ANTONIO, TEXAS

WILLIAM AND PATRICIA COLLINS Appellant

Vs.

DR. OLIVER WILLIAMS Appellee

-■*. -v- 'r'

APPELLANT'S VERIFIED MOTION FOR RECONSIDERATION OF DENIAL OF ORAL ARGUMENT .. v- WITH /^ REQUEST FOR TELEPEHONE HEARING IF NECESSARY (OPPOSED) (Oral Argument Requested)

James R. Chapman, Jr. P. O. Box 841 Fredericksburg, Texas 78624 (830) 997-3269 No Fax Cell (281) 734-8181

ATTORNEY FOR APPELLANTS WILLIAM AND PATRICIA COLLINS APPELLANT'S VERIFIED MOTION FOR RECONSIDERATION OF DENIAL OF ORAL ARGUMENT WITH REQUEST FOR TELEPHONE HEARING IF NECESSARY (OPPOSED) (Oral Argument Requested)

Appellants William and Patricia Collins requests the Court to reconsider its denial of oral argument in this cause, and would show:

1. Appellants are William and Patricia Collins, residents of Gillespie County, Texas.

2. Appellants request the Court to reconsider its decision to deny oral argument,

as oral argument would crystallize the issues, and assist the court in determining the legal and factual issues by not allowing the record to be tainted by extraneous matters.

3. Appellants request the Court to reconsider and grant oral argument in this case.

4. The Appellee's lead Counsel, Jeff Small, was contacted on Thursday, January

15,2015, at 10:27 a.m., regarding opposition or consent. A detailed message was left If

opposition is filed, a telephone hearing is requested at movant's expense.

5. The facts stated herein are within the personal knowledge of counsel who has verified this motion.

WHEREFORE, premises considered, Appellants William and Patricia Collins

through counsel James R. Chapman, Jr., respectfully requests the Court to permit oral argument in this case. Movant prays for general relief.

Respectfully submitted,

Jaines R. Chapman, Jr., 04134700 Attorney for Appellants P. O. Box 841 Fredericksburg, Texas 78624 (830) 997-3269 No Fax Cell (281) 734-8181 VERIFICATION

STATE OF TEXAS COUNTY OF GILLESPIE

ON THIS DAY, personally appeared James R. Chapman, Jr., Attorney for Appellant, and who, identified by me, the undersigned Notary Public by TDL, and personal knowledge, after being duly sworn, deposed and said: "My name is James R. Chapman, Jr., and I am Attorney for Appellant in this suit. I have read the above and foregoing document, and

les R. Chapman, Jr. Iant

To certify which witness my hand and seal of office this /O day of January, 2015. HOLLIE ANN BAKER Notcry Public. State of Texas My Commission Expires Notary Public \'K*

November 24, 2018

CERTIFICATE OF CONFERENCES

I certify that on January 15, 2015,1 called Jeff Small to discuss this motion. He was not available, so a detailed message was left. If opposition is filed, a telephone hearing is requested at Movant's expense. /\ ^j

R. Chapman, Jr.

CERTIFICATE OF SERVICE

I certify a copy of this document was forwarded Certified Mail, Return Receipt Requested on January 15, 2015, to the following persons at the addresses shown, pursuant to the Texas Rules of Appellate ProcejHu^; Z) / p>

es R. Chapman,

Jeff Small SBN 00793027 Ms. Cindy Huggins Attorney for Defendant/Appellee 216th Court Reporter 12451 Starcrest, Suite 100 P.O. Box 293251 San Antonio, Texas 78216 Kerrville, Texas 78028 Tel (210) 496-0611 Fax (210) 579-1399

Ms. Jan Davis, Gillespie County District Clerk Bill and Patricia Collins 101 West Main Street, Room 204 Fredericksburg, Texas 78624 James R. Chapman, Jr. Attorney and Counselor at Law P. O. Box 841 Fredericksburg, Texas 78624 (830) 997-3269 Cell (281) 734-8181

January 15,2015

Mr. Keith Hottle PERSONAL Clerk, Fourth Court of Appeals Cadena-Reeves Justice Center HAND DELIVERY 300 Dolorosa, Suite 3200 San Antonio, Texas 78205-3037 (210) 335-2635 Fax (210) 335-2762

Re: Cause No. 04-14-00491-CV, Collins vs. Williams; Civil Appeal from Gillespie County, Texas,

MOTION FOR RECONSIDERATION ON ORAL ARGUMENT Dear Mr. Hottle:

Please file with the Court, and return a file stamped copy of the document to the undersigned in the stamped, letterhead envelope.

Thank you for your courtesies in this matter. If you have any questions, please contact me at your convenience at the letterhead numbers or address.

All counsel and interested parties have been served with a copy of this document.

Very truly/Yours,

ies R. Chapman, Jr.