NO. 04-14-00562-CV

IN THE TEXAS COURT OF APPEALS FOR THE FOURTH DISTRICT 

SAN ANTONIO, TEXAS 

* * * * * 

JESUS DE LOS SANTOS, JR., Individually and as Representative of the 

ESTATE OF JESUS FRANCISCO DE LOS SANTOS, and JUAN DE LOS 

SANTOS, Appellants; and MARCO ANTHONY SOLIS, JR., Cross-Appellant, 

v. 

FORD MOTOR COMPANY, 

 Appellee 

* * * * * 

On Appeal from the 79th Judicial District Court 

Jim Wells County, Texas 

Trial Court Cause No. 11-08-50394-CV

* * * * * 

APPELLANTS’ UNOPPOSED MOTION FOR LEAVE TO 

FILE POST-SUBMISSION LETTER BRIEF

* * * * * 

THE HONORABLE JUSTICES OF THE COURT:

Jesus De Los Santos, Jr. Individually and as Representative of the Estate of 

Jesus Francisco De Los Santos and Juan De Los Santos, Appellants, respectfully 

presents this motion requesting leave to file the post-submission letter brief attached 

hereto as Exhibit A, which addresses record citations relevant to certain important factual 

questions asked by the Court during the recent oral argument in this matter. In support of 

this motion, Appellants would show the Court as follows:

1. This appeal was submitted on oral argument on Thursday, March 26, 2015. 

2. The case involves complicated technical issues about product 

specifications, metallurgy, and accident reconstruction. 

ACCEPTED

04-14-00562-cv

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

4/6/2015 9:11:16 AM

KEITH HOTTLE

CLERK

 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 4/6/2015 9:11:16 AM KEITH E. HOTTLE Clerk
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3. During the course of the oral argument, the Court had several questions 

about these technical issues, in particular, questions about Ford’s specifications for 

“hardness” and other applicable matters related to planned output for Ford axles. Such 

matters are difficult to succinctly explain in the span of a short oral argument and require 

a review of several portions of the technical and expert testimony in the context of the 

record. Since these factual matters about the content of the record are central to the 

issues raised in this appeal, Appellants request leave to file the attached post-submission 

letter brief to help guide the Court to the relevant portions of the record as they pertain to 

specifications and planned output for Ford axles.

4. Certificate of Conference: On April 2, 2015, the undersigned conferred

via email with Allyson Ho, lead appellate counsel for Appellee Ford Motor Company, 

regarding the relief requested in this motion. Ms. Ho responded that Ford takes no 

position regarding the requested relief. Therefore, this motion is filed as UNOPPOSED.

Respectfully submitted,

By: ________________________________

Brendan K. McBride

State Bar No. 24008900

Brendan.mcbride@att.net

THE MCBRIDE LAW FIRM

 Of Counsel to GRAVELY & PEARSON, LLP

425 Soledad, Suite 620

San Antonio, Texas 78205

(210) 472-1111 Telephone

(210) 881-6752 Facsimile
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And

Jeffrey G. Wigington

State Bar No. 00785246

jwigington@wigrum.com

R. Reagan Sahadi

State Bar No. 24042369

rsahadi@wigrum.com

WIGINGTON RUMLEY DUNN 

 & BLAIR, LLP

123 N. Carrizo St. 

Corpus Christi, Texas 78401

(361) 881-7500

(361) 884-0487 (Facsimile)

COUNSEL FOR APPELLANTS, 

JESUS DE LOS SANTOS, JR. 

INDIVIDUALLY AND AS 

REPRESENTATIVE OF THE 

ESTATE OF JESUS FRANCISCO DE 

LOS SANTOS AND JUAN DE LOS 

SANTOS
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CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing document has been 

forwarded on this 6

th day of April, 2015 to Appellee’s counsel of record, Allyson Ho and 

Cross-Appellant Marco Soliz, Jr.’s lead appellate counsel, Lupita Aguilar, by electronic 

service through Texas.gov.

____________________________________

Brendan K. McBride