No. 01-14-01004-CV 

Kevin Leroy Campbell, § IN THE FIRST 

Appellant, § 

 § 

v. § COURT OF APPEALS 

 § 

M. Brandon Maggiore, Guardian Ad Litem, § 

Appellee. § HOUSTON, TEXAS 

Motion For Leave to File Amended Brief With Appendix

 Pursuant to Texas Rule of Appellate Procedure 38.7, Appellee asks this 

Honorable Court to grant him leave to file an amended brief with an appendix 

(which brief and appendix were filed on the same date as this motion) to correct 

technical and grammatical defects, several statutory and internal reference errors, 

and to include an appendix. 

1. Appellee’s brief was timely filed on October 19, 2015 even though Appellant 

filed an Amended brief only 18 days before Appellee’s brief deadline. 

2. Appellee asks this Court to accept his amended brief and appendix filed on 

October 22, 2015, the same date as this motion. 

3. The amended brief corrects formatting errors in the index, adds the text for the 

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ACCEPTED

01-14-1004-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

10/22/2015 4:44:20 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 10/22/2015 4:44:20 PM CHRISTOPHER A. PRINE Clerk
points on appeal to the index, corrects defects in the table of authorities, 

corrects several statutory and internal reference errors, and adds an appendix. 

4. The Appendix includes all statutes, case law, and orders cited in Appellee’s 

brief.

5. Appellee’s amended brief does not add new points on appeal, new arguments, 

or new case law and, therefore, will cause no delay in the submission of this 

case. 

6. The appendix does not include excerpts from the Reporters Record due to the 

number of pages from this record cited by Appellee. 

7. Appellee believes that the amended brief and appendix thereto will assist this 

Court and Appellant in reviewing the merits of this case.

PRAYER

For the foregoing reasons, Appellee asks the Court to grant Appellee the 

right to file an amended brief with an appendix on or before the date this Court 

rules on this motion.

// 

//

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Respectfully submitted, 

/s/ M. Brandon Maggiore 

M. Brandon Maggiore 

State Bar No.: 24078901 

Maggiore Law Firm, PLLC 

2442 S. Downing St., Suite 100

Denver, CO 80210 

Telephone: (713) 239.3347 

Facsimile: (713) 581.1894 

brandon@maggiorelawfirm.com 

GUARDIAN AD LITEM FOR LONNIE 

PHILLIPS, JR., AN INCAPACITATED 

PERSON 

CERTIFICATE OF COMPLIANCE 

 I certify that this document was produced on a computer using Pages 5.5.3 

and contains 265 words, as determined by the computer software's word-count 

function, excluding the sections of the document listed in Texas Rule of Appellate 

Procedure 9.4(i)(1).

/s/ M. Brandon Maggiore 

M. Brandon Maggiore

State Bar No.: 24078901 

// 

//

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CERTIFICATE OF SERVICE 

 I certify that on October 22, 2015, I served a copy of Appellee’s First 

Amended Motion to Dismiss for Lack of Jurisdiction and Motion for Award of 

Fees and Costs for a Frivolous Appeal on the parties listed below by electronic 

service and that the electronic transmission was reported as complete. My e-mail 

address is brandon@maggiorelawfirm.com.

/s/ M. Brandon Maggiore 

M. Brandon Maggiore

State Bar No.: 24078901 

Veronica L. Davis 

Attorney for Appellants 

Texas Bar No. 05557300 

226 N. Mattson 

West Columbia, Texas 77486 

Telephone: 979.345.2953 

Facsimile: 979.345.5461 

vld57atal@yahoo.com

Catherine N. Wylie 

Guardian Of the Person and Estate of 

Lonnie Phillips, Jr., An Incapacitated 

Person 

The Wylie Law Firm 

2211 Norfolk Street, Suite #440 

Houston, Texas 77098 

Telephone: 713.275.8230 

Facsimile: 713.275.8239 

Email: cwylie@wylielawfirm.com

Dana V. Drexler 

Attorney Ad Litem during the trial on 

the Merits 

1010 Lamar Street, Suite 1450 

Houston, Texas 77002 

Telephone: 713.658.8900 

Facsimile: 713.658.9408 

DVPDrexler@aol.com 

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