NO. 14-14-00492-CV

IN THE

COURT OF APPEALS

FOR THE

14th JUDICIAL DISTRICT

HOUSTON, TEXAS

PAUL STAMATIS, JR.

Appellant

v.

METHODIST WILLOWBROOK HOSPITAL; DANIEL MAO M.D.; AND 

NEPTUNE EMERGENCY SERVICES, P.A.

Appellees 

 

Appeal from

Cause No. 2010-34910, in the 

190TH District Court of Harris County, Texas

___________________________________________________________

APPELLEES’ MOTION FOR LEAVE 

TO FILE POST-SUBMISSION BRIEF

___________________________________________________________

ACCEPTED

14-14-00492-CV

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

5/7/2015 2:16:56 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 5/7/2015 2:16:56 PM CHRISTOPHER A. PRINE Clerk
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TO THE HONORABLE COURT OF APPEALS:

Appellees Houston Methodist Willowbrook Hospital, Daniel Mao, M.D., 

and Neptune Emergency Services, P.A. file this Motion for Leave to File PostSubmission Brief. 

Appellees seek leave to file the three-page Post-Submission Brief submitted 

concurrently herewith to respond to questions posed by the justices at oral 

argument on April 30, 2015 as to the basis of the trial court’s authority to 

determine that the emergency standard of proof applied to Appellant’s claims as a 

matter of law following the pretrial conference. Based on the questions posed by 

the Justices, Appellees believe that a concise brief on this point would assist the 

Court in its deliberations. 

PRAYER FOR RELIEF

For the reasons set forth above, Appellees request that this Court grant their

Motion for Leave to File Post-Submission Brief, direct the clerk to accept and file 

Appellees’ Post-Submission Brief, and grant them all other relief to which they

may be entitled.
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Respectfully submitted,

DE LA ROSA LAW FIRM

/s/ Oscar L. De la Rosa

Oscar L. De la Rosa

State Bar No. 00787351

odelarosa@delarosalawfirm.com

Aron L. Gregg

State Bar No. 24027214

agregg@delarosalawfirm.com

Three Riverway, Suite 1820

Houston, Texas 77056

(713) 395-0991

(713) 395-0995 (fax)

ATTORNEYS FOR APPELLEE, 

HOUSTON METHODIST 

WILLOWBROOK HOSPITAL

CARDWELL & CHANG, P.L.L.C.

By:______________________________

LaVerne Chang

State Bar No. 00783819

511 Lovett Blvd.

Houston, Texas 77006

Telephone: (713) 222-6025

Facsimile: (713) 222-0938

ATTORNEYS FOR APPELLEES

DANIEL MAO, M.D. AND NEPTUNE 

EMERGENCY SERVICES, P.A.
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CERTIFICATE OF CONFERENCE

As required by Texas Rule of Appellate Procedure 10.1(a)(5), I certify that I 

have conferred, or made a reasonable attempt to confer, with all other parties, 

which are listed below, about the merits of this motion with the following results:

Craig Lewis, Counsel for Appellant, 

[X] opposes motion

[ ] does not oppose motion

[ ] agrees with motion

[ ] would not say whether motion is opposed

[ ] did not return my message regarding the motion.

/s/ Oscar L. De la Rosa

LaVerne Chang, Counsel for Daniel Mao, M.D. and Neptune 

Emergency Services, P.A.

[ ] opposes motion

[ ] does not oppose motion

[X] agrees with motion

[ ] would not say whether motion is opposed

[ ] did not return my message regarding the motion.

/s/ Oscar L. De la Rosa

Date: May 7, 2015
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CERTIFICATE OF SERVICE

As required by Texas Rules of Appellate Procedure 6.3 and 9.5(b), (d), (e), I 

certify that I have served this document on all other parties—who are listed 

below—on the 7th day of May, 2015 by facsimile and electronic service.

Counsel for Appellant Paul Stamatis, Jr.:

Craig Lewis

The Lewis Law Firm

2905 Sackett Street

Houston, Texas 77098

Facsimile: 713-328-7888

Counsel for Daniel Mao, M.D. and Neptune Emergency Services, P.A.:

La Verne Chang

Cardwell & Chang

511 Lovett Blvd.

Houston, Texas 77006

Facsímile: 713-222-0938

/s/ Oscar L. De la Rosa