Houston,T Houston, X 77046 TX 77046/s/
M.Ross /s/ Philip M. Ross Philip M.Ross Philip M. Ross
Silverado Appx. 0489 No. 1-15-586-CV 3779 TAB 59 FILED FILED 12/18/2014 PM 12/18/2014 4:44:26 PM n Stan Stanart DATA-ENTRY County Clerk County Harris County · PICK UP THIS DATE
CAUSENO.427,208 CAUSE NO. 427,208 PROBATE COURT PROBATE COURT 1
MACKEY MACKEY ("MACK") GLEN ("MACK") GLEN PETERSON § PETERSON INPROBATE IN COURT PROBATE COURT NO.l1 NO. PETERSON; TONYAPETERSON PETERSON; TONYA PETERSON § Individually and as NextFriend and as of Next Friend of § RUBYPETERSON; RUBY PETERSON;DONLESLIE DON LESLIEPETERSON;§ PETERSON; § CAROL CAROL PETERSON, PETERSON, andas Individually and asNext Next §§ Friend Friend ofRUBY of RUBY PETERSON; PETERSON; and LONNY and LONNY § PETERSON, PETERSON, § VS. VS. § § SILVERADO SILVERADO SENIOR SENIOR LIVING, INC. LIVING, INC. § SILVERADO d/b/a SILVERADO SENIOR SENIOR LIVING LIVING - - § SUGAR SUGAR LAND LAND § HARRIS COUNTY, HARRIS COUNTY, TEXAS TEXAS
SILVERADO'S SILVERADO'S RESPONSE RESPONSE TO TO PLAINTIFFS' PLAINTIFFS' OBJECTION OBJECTION TO APPLICATION FORATTORNEY'S TOAPPLICATION FEES FOR ATTORNEY'S FEES PURSUANT PURSUANT TORULE TO ENTERED RULE 91(a) ENTERED ONNOVEMBER2014 ON NOVEMBER 10, 2014
Defendant,Silverado Defendant, Silverado SeniorLiving,Inc. d/b/aSilverado Senior Living, Inc. d/b/a SeniorLivingSugarLand Silverado Senior Living Sugar Land
(Silverado)files thisResponse (Silverado) to Plaintiffs' this Response to Objection Plaintiffs' Objection ttooApplication Application forAttorney's FeesPursuant for Attorney's Fees Pursuant
to Rule91(a) to Rule 9l(a)Entered Entered On November OnNovember (Plaintiffs' I0,20141 (Plaintiffs' 10, Objection) Objection) Ordered asOrdered as bytheCourt by and the Court and
expressly agreedby expresslyagreed bytheparties December onDecember the parties on 9,2014.I 9, 2014.
PROCEDURAL PROCEDURAL POSTURE POSTURE
OnNovember On 10,2014, November 10, 2014,the Court entered theCourt itsOrder entered its granting Silverado's Order granting Rule91a Silverado's Rule 9laMotion Motion to to
Dismiss Dismiss thefollowing causes the following causes ofaction of whichwere action which theonly werethe causes only causes ripeforinclusion ripe intheinitial for inclusion in the initial
falseimprisonment, 91afiling: false 91a imprisonment, assault assault andbattery, and battery, andconspiracy. Silverado and conspiracy. Silverado timelyfiled its timely its Application Application forAttomey for FeesPursuant Attorney Fees Pursuant Rule91a toRule to 9laOrder Entered Order Entered onNovember on 10,20142 and November 10, and First First
Supplement Supplement (hereinafter thereto3 (hereinafter globally globally referred referred to as "Silverado's to as "Silverado's Fee Application") FeeApplication") required asrequired as
1 Onfile with On withthe theCourt andincorporated Court and byreference incorporated by asififset reference as setout fullyherein. out fully herein. 2 Id. 3 id
4844-7770-7809.1
Silverado Appx. 0490 No. 1-15-586-CV 3780 bytheCourt by andpursuant the Court and to Rule pursuant to Rule 91a.The onlyother 91a. The only otherpending pending motion motion issuerelated atissue at related theRule ttoothe Rule
entered 91aOrder onNovember Motion isPlaintiffs 10,2014 toReconsider, Brief inSupport and 91a Order entered on November 10, 2014 is Plaintiffs Motion to Reconsider, Brief in Support and
Silverado's Silverado's Response Response thesame.4 tothe to
II RULE 11
OnDecember On December 9,2014, during tthe 9, 2014, during hehearing onSilverado's hearingon FeeApplication, Silverado's Fee Application, theCourt the Court afforded
Plaintiffs Plaintiffs opportunity anopportunity an totochoose choose themethod the bywhich method by thefeeapplication which the fee application