MOOR1VIAN TATE HALEY UPCHURCH & YATES, LLP 

R. HAL MOORMAN*t 

STEVEN C. HALEY 

LAURA UPCHURCH 

WENDY YATES* 

ATTORNEYS AT LAW 

207 EAST MAIN STREET 

BRENHAM, TEXAS 77833 

P.O. BOX 1808 

BRENHAM, TEXAS 77834-1808 

(979) 836-5664 

FAX (979) 830-0913 

www.moormantate.com 

BOARD CERTIFIED 

*ESTATE PLANNING & PROBATE LAW 

tCIVIL TRIAL LAW 

TEXAS BOARD OF LEGAL SPECIALIZATION 

GEORGE R. MOORMAN (1919-2011) 

ANDREW J. HEFFERLY MILTON Y. TATE, JR. (RETIRED) 

CHRISTOPHER S. HARDY 

July 31, 2015 

Fourth Court of Appeals 

Cadena-Reeves Justice Center 

300 Dolorosa, Ste. 3200 

San Antonio, Texas 78205-3037 

RE: El Caballero Ranch, Inc. and Laredo Marine, L.L.C. v. Grace River Ranch, 

LLC; No. 04-15-00127CV, 4thJudicial District, San Antonio, Texas 

Dear Justices of the Fourth Court of Appeals: 

By way of supplement of the Brief of Appellee filed herein, Grace River Ranch, 

LLC (Grace River) provides the following additional argument: 

La Salle County No Longer a Party to the Suit Below 

With No Pending Affirmative Claims 

Appellants, by their Brief, stated that La Salle County was a party to the 

proceeding below and had filed an affirmative pleading asserting it was improper 

for the trial court to enter a Partial Summary Judgment that the disputed road was a 

public road (Appellants Brief at 27). Although not indicated by Appellants' Brief, 

La Salle County filed below its Plea to the Jurisdiction claiming that the county was 

immune from Appellants' third party claim on the basis of sovereign immunity. That 

{18705.43065-00395933.DOCX} 

ACCEPTED

04-15-00127-CV

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

7/31/2015 3:31:16 PM

KEITH HOTTLE

CLERK

 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 07/31/15 3:31:16 PM KEITH E. HOTTLE Clerk
affirmative e aim seeking 

Sincerely, 

July 31, 2015 

Page 2 

Plea to the Jurisdiction was recently granted by the trial court on July 27, 2015. 

Order — Plea to the Jurisdiction dated July 27, 2015 [Exhibit A].' La Salle County 

is no longer a party to the suit below. La Salle County no longer has any pending 

ny modification of the Partial Summary Judgment. 

STEVEN C. HALEY 

SCH:mb 

Enclosures 

CC: Annalyn G. Smith 

Schmoyer Reinhard, LLP 

17806 I-10W, Ste. 400 

San Antonio, Texas 78257 

E-mail: asmith@ar-11p.com 

Kimberly S. Keller 

Keller Stolarczyk PLLC 

234 West Bandera Road, No. 120 

Boerne, Texas 78006 

E-mail: kim@kellsto.com 

1Grace River has requested the La Salle County District Clerk's Office to supplement the 

Appellate Record as soon as possible with a copy of this recent Order — Plea to the Jurisdiction. 

{18705.43065-00395933.DOCX} 
July 31, 2015 

Page 3 

Donato Ramos, Jr. 

Law Offices of Donato D. Ramos, P.L.L.C. 

Texas Community Bank Building 

6721 McPherson, Suite 350 

Laredo, Texas 78041 

E-mail: donatoramosjr@ddrlex.corn 

{18705.43065-00395933.DOCX} 
EXHIBIT A 
u ITA A. ESQUUNTY & DISTRICT G.' ,Alt LA SALLE GOUNTIC TEXAS' 

DEPUTY 

SUAN t 

CAUSE NO. 13-04-00108-CVL 

GRACE RIVER RANCH, LLC IN THE DISTRICT COURT 

V. 

EL CABALLERO RANCH, INC. A/K/A 

EL CABALLERO, LLC AND LAREDO 218th JUDICIAL DISTRICT 

MARINE, L.L.C. 

V. 

COUNTY OF LA SALLE LASALLE COUNTY, 'IOAS 

ORDER — PLEA TO THE JURISDICTION 

On April 1, 2015, came on for hearing the Plea to the Jurisdiction filed herein by Third Party 

Defendant COUNTY OF LA SALLE ("La Salle County"). Plaintiff GRACE RIVER RANCH, 

LLC, Defendants/Third Party Plaintiffs EL CABALLERO RANCH, INC. a/k/a EL 

CABALLERO, LLC and LAREDO MARINE, LLC, (collectively "El Caballero"), and Third 

Party Defendant La Salle County each appeared by and through counsel. 

The Court having considered the pleadings, arguments and evidence presented, SUSTAINS 

the Plea to the Jurisdiction. All claims for relief of El Caballero against La Salle County are 

dismissed. 

Rendered and Signed July 27, 2015. 

Judge Presiding 

VOL. 101 PAGE 2