NO. 04-014-00494-CV

IN THE FOURTH COURT OF APPEALS 

SAN ANTONIO, TEXAS

UNITED PARCEL SERVICE, INC. and ROLAND LEAL

Appellants/Cross-Appellees

v.

ROBERT SCOTT RANKIN, Individually; RACHELLE RANKIN,

Individually and as Next Friend for AVERY RANKIN, a Minor; as Next

Friend for KARA RANKIN, a Minor; and as Next Friend for SAMUEL

RANKIN, a Minor

Appellees/Cross-Appellants

On Appeal from the 224 Judicial District Court, Bexar County, Texas th

Honorable Cathy Stryker, Presiding Judge

Trial Court Cause No. 2011-CI-07922

CROSS-APPELLANTS’ UNOPPOSED MOTION FOR LEAVE TO FILE

REPLY TO CROSS-APPELLEES’ SURREPLY TO ARGUMENT IN

CROSS-APPELLANTS’ REPLY BRIEF THAT RULE 167.4(a) IS INVALID

TO THE HONORABLE COURT OF APPEALS:

Cross-Appellants, Robert Scott Rankin, Rachelle Rankin, Avery Rankin, Kara

Rankin, and Samuel Rankin (the “Rankins”), by and through their undersigned

CROSS-APPELLANTS’ UNOPPOSED MOTION FOR LEAVE TO FILE REPLY TO CROSS-APPELLEES’ SURREPLY

TO ARGUMENT IN CROSS-APPELLANTS’ REPLY BRIEF THAT RULE 167.4(a) IS INVALID - Page 1 of 4

ACCEPTED

04-014-00494-CV

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

4/17/2015 5:48:09 PM

KEITH HOTTLE

CLERK

 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 4/17/2015 5:48:09 PM KEITH E. HOTTLE Clerk
attorneys, hereby move the Court for an Order allowing them to file a Reply to CrossAppellees’ Surreply to Argument in Cross-Appellants’ Reply Brief That Rule

167.4(a) is Invalid, and in support thereof would respectfully show the Court the

following:

The Court granted Cross-Appellees’ Motion for Leave to File Reply to New

Argument inCross-Appellants’ Reply Brief That Rule 167.4(a) isInvalid on April 14,

2015. Cross-Appellants request that the Court allow them to file their Reply to

Cross-Appellees’ Surreply in that it will assist the Court by providing argument and

authority. Cross-Appellees are not opposed to Cross-Appellants’ Motion for Leave.

WHEREFORE, Cross-Appellants pray that thisCourt grant themleave to file

their reply to Cross-Appellees’ Surreply to Argument in Cross-Appellants’ Reply

Brief That Rule 167.4(a) isInvalid, which is being electronically filed simultaneously

with this Motion, and for such other and further relief as the Court may deem to be

just and proper.

CROSS-APPELLANTS’ UNOPPOSED MOTION FOR LEAVE TO FILE REPLY TO CROSS-APPELLEES’ SURREPLY

TO ARGUMENT IN CROSS-APPELLANTS’ REPLY BRIEF THAT RULE 167.4(a) IS INVALID - Page 2 of 4
Respectfully submitted,

THE PERRIN LAW FIRM

1910 Pacific Avenue, Suite 6050

Dallas, Texas 75201

Telephone: (214) 646-2004

Facsimile: (214) 646-6117

Email: dougperrin@perrinlaw.org

 markperrin@perrinlaw.org

/s/J. Mark Perrin 

Doug Perrin

State Bar No. 15796520

J. Mark Perrin

State Bar No. 24013313

REESE GORDON MARKETOS LLP 

750 N. St. Paul Street, Suite 610 

Dallas, Texas 75201

Telephone: (214) 382-9810

Facsimile: (214) 501-0731

Email: pete.marketos@rgmfirm.com

Pete Marketos

State Bar No. 24013101 

KEELING & DOWNES, P.C.

1500 McGowen Street

Houston, Texas 77004

Telephone: (832) 214-9900

Fax: (832) 214-9908

Email: bck@keelingdownes.com

Byron Keeling

State Bar No. 11157980

ATTORNEYS FOR 

CROSS-APPELLANTS

CROSS-APPELLANTS’ UNOPPOSED MOTION FOR LEAVE TO FILE REPLY TO CROSS-APPELLEES’ SURREPLY

TO ARGUMENT IN CROSS-APPELLANTS’ REPLY BRIEF THAT RULE 167.4(a) IS INVALID - Page 3 of 4
CERTIFICATE OF CONFERENCE

I have conferred with counsel for Cross-Appellees about the merits of this

Motion and was advised that Cross-Appellees do not oppose the relief requested in

this Motion. 

Certified this 17 day of April, 2015. 

th

/s/J. Mark Perrin 

J. Mark Perrin

CERTIFICATE OF SERVICE

This will certify that a true and correct copy of the above and foregoing

document was forwarded to all counsel of record in the above cause through the

Court’s electronic case filing system, on this the 17 day of April, 2015.

th

Ricardo Reyna

Audrey Haake

Brock, Person, Guerra, Reyna P.C.

17339 Redland Road

San Antonio, Texas 78247

W. Randall Bassett

Bradley Pratt

King & Spalding, LLP

1180 Peachtree Street, NE

Atlanta, Georgia 30309

H. Victor Thomas

King & Spalding, LLP

1100 Louisiana, Suite 4000

Houston, Texas 77002

/s/J. Mark Perrin 

CROSS-APPELLANTS’ UNOPPOSED MOTION FOR LEAVE TO FILE REPLY TO CROSS-APPELLEES’ SURREPLY

TO ARGUMENT IN CROSS-APPELLANTS’ REPLY BRIEF THAT RULE 167.4(a) IS INVALID - Page 4 of 4