NO.Ol-15-00073-CV

IN THE MATTER OF THE MARRIAGE OF § 

### § § § 

### § § IN THE FIRST COURT

CORNELIS P. WILLIG 

### AND l\fARCELA GUTIERREZ DIAZ OF APPEALS HOUSTON, TEXAS

APPELLANT CORNELIS P. 'WILLIG'S MOTION FOR LEAVE OF COURT TO FILE A CORRECTED BRIEF Appellant Cornelis P. Willig hereby asks the Court to grant this Motion allowing the Appellant to file a corrected brief in the appeal of this case so that the brief filed by the Appellant can include the one page that was accidentally omitted and not included in the brieftha1 was filed. A. Introduction 1. Appellant's attorney inadvertently omitted including in the brief that was timely efiled with the Court the inclusion of what should have been the true third page of the brief s Statement of Facts. Appellant's attorney could not overcome the electronic barriers that the word processor used in preventing the attorney from numbering the pages of the brief from the beginning of the section as the Statement of Facts to the end .ofthe brief itself 2. For that reason, Appellant's attorney took the brief to the First Court of Appeals showing the lack of numeration from that point in the brief to

### its conclusion and presented ti an assistant of the Court at the Intake station. The Intake Staff at the Court advised Appellant's attorney that it was permissible and would not harm the brief tohand number those pages since the attorney had not been able to have the computer do so because of reasons that to this moment, the attorney does not comprehend, even with the assistance of his legal secretary ACCEPTED 01-15-00073-CV FIRST COURT OF APPEALS

HOUSTON, TEXAS 7/9/2015 9:59:26 AM CHRISTOPHER PRINE

CLERKand her experience.

3. Appellant's attorney returned tohis office and started to hand number the referenced pages. Somehow, in the process of numbering the pages, the page that should have been page number 3 was separated from the other pages and was not included in the brief. Presently numbered as page 3 is what should have been, ifthe numeration would have been properLy done, page 4. Page 3 was omitted from the numeration, not included inthe brief when filed, and the remaining subsequent pages of the brief all reflect being one page off from what should have been the proper page number if page 3 would have been included in the contents. 4. The filed brief does notinclude the contents ofpage 3atthe present time and all subsequent pages reflect apage number that isone page offfrom the contents ofthe brief as written. The contents ofthat page are ofimportance to the concepts that were presented inthe brief and there is now a gap in the presentation ofthe concepts in the Statement of Facts because of the omission ofpage 3. 4. Appellant's attorney was extremely careful inconsolidating thebrief andtook much care in attempting to insure that a mistake such as this would not happen. Somehow, for some
reason or act that Appellant's attorney is not aware of, the error occurred, for which error Appellant's attorney apologizes to the Court. B. Prayer 6. For these reasons, Appellant asks the leave of the Court requesting that the Court grant Appellant the filing of the brief as a corrected brief, this time fully including in the filed document the missing page 3and the full content that should have been correctly flied with
2the Court originally. Appellant also requests that the Court permit Appellant to make a

correction intherepagination ofthe brieftocorrectly reflect thetrue location ofthe complete contents ofthe brief once page 3 is included. Respectfully Submitted, 

## ~""\- ~ PeJl.-.-J} Andres P. Chaumont State 

### BarNo.: 15779400 834 Fleetwood Place Houston" Texas 77079 Tel: (281) 493-3999 Fax: (281) 493-3993 Email: anchlaw88@gmail.com Attorney for Appellant CERTIFICATE OF SERVICE Icertify that acopy ofAppellant's Motion for Leave ofCourt to File a Corrected Brief was served on Appellee's counsel ofrecord, Mr. Michael Busby, 2909 Hillcroft, Suite 350, Houston, Texas 77057; Fax: 713-974-1181 by telephonic documenttransfer to said fax number on July 9, 2015. 

# JJLc......p.~ Andres P

_Chaumont Attorney for Appellant