                                                                                         ACCEPTED
                                                                                    04-14-00167-CV
                                                                         FOURTH COURT OF APPEALS
                                                                              SAN ANTONIO, TEXAS
                                                                                3/9/2015 2:43:05 PM
                                                                                      KEITH HOTTLE
                                                                                             CLERK

                            No. 04-14-00167-CV
                                   In the                            FILED IN
                          Fourth Court of Appeals             4th COURT OF APPEALS
                           at San Antonio, Texas               SAN ANTONIO, TEXAS
                                                              03/9/2015 2:43:05 PM
                          ____________________                  KEITH E. HOTTLE
                                                                      Clerk
                  Stephens & Johnson Operating Co., et al.,
                                Appellants,
                                      vs.
                         Charles W. Schroeder, et al.,
                                 Appellees.
                          ____________________
                  Appealed from the 229th District Court of
                         Jim Hogg County, Texas
                           Cause No. CC-04-143


                             Appellees’ Brief


Baldemar Garcia Jr.
Texas Bar No. 00790740
email: bgarcia@personwhiworth.com
lead appellate counsel for appellees
Martha Cigarroa de Llano
Texas Bar No. 04250800
email: mdellano@personwhitworth.com
PWBM, LLP
602 East Calton Road, 2nd Floor (78041)
P. O. Drawer 6668 (78042)
Laredo, Texas
voice 956.727.4441
facsimile 956.727.2696
Appellees Conditionally Request Oral Argument
Table of Contents
Index of Authorities....................................................................................................3
Statement of the Case .................................................................................................5
Statement Regarding Oral Argument ........................................................................5
Replies to Issues Presented.........................................................................................6
   1. Generally speaking, an oil and gas lease terminates if there is no drilling
   activity or production after the expiration of its primary term. Schroeder presented
   an expert witness affidavit proving no drilling or production after the primary term
   on the Stephens & Johnson Operating Co. lease. Stephens & Johnson Operating
   Co. did not file an opposing affidavit. Was the declaration of termination by
   summary judgment proper? ................................................................................... 6
   2. Reasonable attorneys’ fees are provable by billing records showing the date,
   rate, number of hours, and description of work. Opposing affidavits cannot be
   conclusory. Schroeder offered their attorneys’ affidavit and billing records.
   Stephens & Johnson Operating Co. filed a counter-affidavit characterizing the fees
   as excessive and unreasonable, but did not challenge the hourly rates or specifically
   object to any of the submitted hours. Did the summary judgment attorneys’ fees
   award constitute an abuse of discretion? ............................................................... 6
Statement of Facts.......................................................................................................6
   I. Record References ............................................................................................. 6
   II. The 10 Year Lease Termination Odyssey .......................................................... 6
Summary of Argument ...............................................................................................9
Argument ................................................................................................................... 10
   I. Unchallenged Declaratory Judgment on Lease Termination ............................. 10
   II. Attorneys’ Fees ............................................................................................... 11
       A. Standard of Review .................................................................................... 11
       B. Reasonableness Factors ............................................................................... 11
       C. Proving Reasonable Fees ............................................................................. 12
       D. Challenging Fees ......................................................................................... 13
       E. Schroeders’ Reasonable and Necessary Attorneys’ Fees .............................. 14



                                                       Page 2 of 18
Prayer.......................................................................................................................... 15
Certificate of compliance ........................................................................................ 16
Appendix.................................................................................................................... 18



Index of Authorities
Cases

Arthur Andersen & Co. v. Perry Equip. Corp., 945 S.W.2d 812 (Tex. 1997) ........... 11
Arthur J. Gallagher & Co. v. Dieterich, 270 S.W.3d 695 (Tex. App.—Dallas 2008,
 no pet.) ................................................................................................................... 11
Basin Credit Consultants, Inc. v. Obregon, 2 S.W.3d 372 (Tex. App.—San Antonio
  1999, pet. denied) ...................................................................................... 12, 13, 14
Bexar County v. Deputy Sheriff ’s Ass’n, 429 S.W.3d 673 (Tex. App.—San Antonio
  2014, no pet.) ......................................................................................................... 10
Bocquet v. Herring, 972 S.W.2d 19 (Tex. 1998) ......................................................... 10
Cammack the Cook, LLC v. Eastburn, 296 S.W.2d 884 (Tex. App.—Texarkana
  2009, pet. denied) .................................................................................................. 13
City of Laredo v. Montano, 414 S.W.3d 731 (Tex. 2013) .................................... 12, 14
Clearview Properties, L.P. v. Property Tex. SC One Corp., 287 S.W.3d 132 (Tex.
  App.—Houston [14th Dist.] 2009, pet. denied) ................................................. 12
El Apple I, Ltd. v. Olivas, 370 S.W.3d 757 (Tex. 2012) ............................... 11, 12, 14
Goode v. Shoukfeh, 943 S.W.2d 441 (Tex. 1997) ....................................................... 10

Holman v. Meridian Oil, Inc., 988 S.W.2d 802 (Tex. App.—San Antonio 1999, pet.
 denied) .................................................................................................................... 10
Jarvis v. Rocanville Corp., 298 S.W.3d 305 (Tex. App.—Dallas 2009, pet. denied) 11

Kidd v. Hogett, 331 S.W.2d 515 (Tex. Civ. App.—San Antonio 1959, writ ref ’d
  n.r.e.) ....................................................................................................................... 10


                                                         Page 3 of 18
Rapid Settlements, Ltd. v. Settlement Funding, LLC, 358 S.W.3d 777 (Tex. App.—
  Houston [14th Dist.] 2012, no pet.) ..................................................................... 11
State & Cnty. Mut. Fire Ins. Co. ex rel. So. United Gen. Agency of Tex. v. Walker, 228
  S.W.3d 404 (Tex. App.—Fort Worth 2007, no pet.) ......................................... 11
Rules

TEX. DISCIPLINARY R. PROF. CONDUCT 1.04 ........................................................ 11
TEX. R. APP. P. 9.4 ..................................................................................................... 15
TEX. R. APP. P. 9.5 ..................................................................................................... 16


                                             No. 04-14-00167-CV
                             Stephens & Johnson Operating Co., et al.,
                                           Appellants,
                                                            vs.
                                        Charles W. Schroeder, et al.,
                                                Appellees.


                                               Appellees’ Brief


To the Honorable Fourth Court of Appeals:

Now Come appellees (1) Charles W. Schroeder; (2) Elsie A. Schroeder-
Schneider; (3) Hollis London; (4) Terry Mengers-Reel; (5) Ted Mengers; (6)
Debbie Mengers-Quates; (7) August H. Steinmeyer; (8) Carole Schroeder-
Miller; (9) James M. Schroeder; (10) Sally Schroeder-Tinanus; (11) James E.
Schroeder; (12) Sue Schroeder-Stanford; (13) Bill Schroeder; (14) Wayne
Hennecke; (15) Diane Hennecke-Rhodes; (16) Jerri James; (17) W. Tom Haley;



                                                     Page 4 of 18
and (18) Peggy Hailey and file this their brief, and in support thereof, would
respectfully show unto the Appellate Court as follows, to-wit:

Statement of the Case
This appeal seeks review of a summary judgment declaring the termination of
a 43-year-old oil and gas lease and awarding related attorneys’ fees and costs.

Statement Regarding Oral Argument
Appellant Genessee did not request oral argument, but the other 16 appellants
did. All 18 appellees join the request for oral argument from the 16 appellants,
and concede to submission without oral argument per appellant Genessee.




                                   Page 5 of 18
Replies to Issues Presented

1.     Generally speaking, an oil and gas lease terminates if there is no
drilling activity or production after the expiration of its primary term.
Schroeder presented an expert witness affidavit proving no drilling or
production after the primary term on the Stephens & Johnson Operating
Co. lease. Stephens & Johnson Operating Co. did not file an opposing
affidavit. Was the declaration of termination by summary judgment
proper?

2.    Reasonable attorneys’ fees are provable by billing records showing
the date, rate, number of hours, and description of work. Opposing
affidavits cannot be conclusory. Schroeder offered their attorneys’
affidavit and billing records. Stephens & Johnson Operating Co. filed a
counter-affidavit characterizing the fees as excessive and unreasonable,
but did not challenge the hourly rates or specifically object to any of the
submitted hours. Did the summary judgment attorneys’ fees award
constitute an abuse of discretion?


Statement of Facts

I. Record References
Three clerk’s records were filed in this appeal: (1) Vol. 1 dated 4/10/2014
consisting of pages 1-168; (2) Vol. 2 dated 4/10/2014 consisting of pages 1-
293; and (3) Vol. 1 dated 5/1/2014 consisting of pages 1-348. In addition to
non-exclusive and thus duplicative numbering, there is also extensive
duplication of pleadings and documents amongst the three records. To ensure
completeness at the risk of inefficiency, all record references in this brief will
be to the last filed record on 5/1/2014 numbered 1-348.

II. The 10 Year Lease Termination Odyssey
A little over ten years ago, 18 plaintiffs/appellees (collectively “Schroeder”)
filed suit seeking the termination of a May 1, 1972 oil and gas lease on 306.71



                                    Page 6 of 18
acres of land located in Jim Hogg County, Texas. (CR at 1-9) The initial basis
of termination was an unexplained 7-month total cessation of oil and gas
production (from July 2003 to January 2004) without any drilling activity that
occurred 26 years after the 5-year primary term had expired. (CR 5-6)

After a year of adding approximately 30 defendants in the 1st and 2nd amended
petitions, Schroeder then moved for summary judgment in mid 2007. (CR at
12-25; 49-61; 63-68) The goal of the summary judgment motion was a
declaration that the oil gas lease expired and plaintiffs were entitled to
attorneys’ fees. (CR at 63-68) The summary judgment motion attached as an
appendix: (1) the subject oil and gas lease, (2) a petroleum engineer’s report
with pertinent Texas Railroad Commission documents establishing the
complete cessation of production, and (3) an attorney’s affidavit regarding
associated fees. (CR at 66; 71-73 [lease]; 74-75 [report]; 76-115 [RRC
supporting documentation]; 116-18 [attorneys’ fees]) The appendix was
incorporated by reference in the motion, and the motion expressly referred to
the “affidavit of Martha Cigarroa de Llano in support of attorney’s fees and
costs expended herein.” (CR at 66)

Defendant/appellant Genessee filed a 4-page response questioning the
authenticity of the lease, lodging hearsay objections to unidentified RRC
documents, and attaching an affidavit disagreeing with the amount of
Schroeder’s attorneys’ fees. (CR at 124-128) The opposing attorney’s fees
affidavit did not challenge the hourly rate claimed by Schroeder’s counsel, nor
did it state how many hours would have been reasonable and necessary. (CR at
130) Some of the co-defendants/appellants adopted the response filed by




                                    Page 7 of 18
Genessee. (CR at 164 [6], 171 [1], 174-75 [1], 178-79) A counter-report
regarding cessation of production was not provided.

Before their summary judgment could be heard, plaintiffs amended their
petition for a third time. (CR 133-47)

By early 2013, plaintiffs filed a fourth amended their petition and supplemented
their motion for summary judgment asserting non-production from July 1,
2003 to January 31, 2004 and from April 2005 to the present. (CR at 214-228;
242-47) The legal basis for the summary judgment remained the same:

   • the standard, express language of the lease requiring production to
      perpetuate the lease (CR at 245-46; 71-73);
   • the easily-controvertible but uncontested affidavits of a petroleum
      engineer demonstrating the 7-month lack of production between July
      2003 and January 2004 and thereafter the non-production from April
      2005 to the present, as documented by the attached Texas Railroad
      Commission records (CR at 253-56; 270-79; 76-115); and
   • resulting attorneys’ fees described by affidavit and detailed by an
      authenticated, 11-page billing statement detailing each expense and
      itemizing every billing entry by date, description, applicable rate, and
      increment of time in tenth or quarter hour. (CR at 257-58, 259-69)

The supplemental motion incorporated by reference the attached appendix
consisting of the lease, the engineers’ affidavits and supporting RRC
documents, and the attorney’s affidavit and billing records “in support of
attorney’s fees and costs expended.” (CR at 244-45) Defendants/appellants
filed a new response complaining that the request for termination was vague



                                   Page 8 of 18
and objecting to Schroeders’ attorneys’ fees. (CR at 280-86, 290, 296) Again,
the opposing affidavits did not challenge the hourly rates charged by
Schroeders’ counsel or state how many hours would have been reasonable and
necessary. (CR at 289, 295)

On December 11, 2013, being a little over 10 years after suit was originally
filed, the trial court granted summary judgment on Schroeders’ termination
claim based on cessation of production. (CR at 298-301) Attorneys’ fees and
costs of $63,787.95 were awarded only against appellant/defendant Stephens &
Johnson Operating Co. (CR at 300)

Summary of Argument
The underlying litigation was filed over 10 years ago, and the substance of the
summary judgment being reviewed has been on file for 7 ½ years. The trial
court declared terminated a 1972 oil and gas lease for a cessation of production
occurring from 2003-2004 and then from 2005 to present. The summary
judgment movants/appellees Schroeder proved termination by expert witness
affidavits and supporting Texas Railroad Commission documents. The non-
movants/appellants opposed summary judgment but did not attach counter-
affidavits. The appellants now do not appear to oppose termination by
summary judgment in their briefs to this Appellate Court.

In addition to success on their request for a declaration of termination,
Schroeder was awarded attorneys’ fees against appellant Stephens & Johnson
Operating Co. only. Schroeders’ attorneys’ fees proof consisted of an affidavit
and supporting billing records showing the date, rate, amount of time, and
description of services for every fee entry. Appellant Stephens & Johnson



                                   Page 9 of 18
Operating Co. filed an opposing affidavit that complained of attorneys’ fees
generally but not addressing any single entry specifically. The trial court did not
abuse its discretion in awarding attorneys’ fees.

Argument

I. Unchallenged Declaratory Judgment on Lease Termination
By their briefs in this Appellate Court, appellants for the first time admit there
is no dispute or justiciable controversy as to the cessation of production and
consequently concede termination of the subject oil and gas lease. (Appellants
Stephens & Johnson Operating Co.’s brief, p. 4-9; Appellant Genessee’s brief, p.
4-6) These concessions were not made in the trial court, where appellants
sought the denial of Schroeders’ summary judgment motions. (CR at 281-82,
292)

Schroeder attached to their summary judgment motions an expert affidavit and
supporting RRC documentation proving a termination due to a cessation of
production since April 2005; appellants did not provide any opposing summary
judgment proof. Appellants also did not submit any summary judgment proof
to show that the terminated oil and gas lease had been released, which would
have mooted any possible controversy. Kidd v. Hogett, 331 S.W.2d 515, 517 (Tex.
Civ. App.—San Antonio 1959, writ ref ’d n.r.e.); Holman v. Meridian Oil, Inc., 988
S.W.2d 802, 805-06 (Tex. App.—San Antonio 1999, pet. denied); (CR at 226)

Without controverting evidence raising a fact issue, a summary judgment
declaration that resolved a disputed lease termination was proper.




                                   Page 10 of 18
II. Attorneys’ Fees

A. Standard of Review
Abuse of discretion is the standard of review for an award of attorneys’ fees in
a declaratory judgment action. Bocquet v. Herring, 972 S.W.2d 19, 21 (Tex. 1998).
A trial court abuses its discretion when it rules arbitrarily, unreasonably, or
without regard to guiding legal principles. Goode v. Shoukfeh, 943 S.W.2d 441, 446
(Tex. 1997). There are four limitations on the trial court’s discretion: the fees
must be (1) reasonable, (2) necessary, (3) equitable, and (4) just. Bocquet, 972
S.W.2d at 21. Reasonableness and necessity are questions of fact; equity and
justness are questions of law. Bexar County v. Deputy Sheriff ’s Ass’n, 429 S.W.3d
673, 677 (Tex. App.—San Antonio 2014, no pet.).

B. Reasonableness Factors
In assessing the reasonableness of an attorneys’ fee award, eight non-exclusive
factors can be considered:

       (1) the time and labor required, the novelty and difficulty of the
       questions involved, and the skill required to perform the legal
       service properly;
       (2) the likelihood … that the acceptance of the particular
       employment will preclude other employment by the lawyer;

       (3) the fee customarily charged in the locality for similar legal
       services;
       (4) the amount involved and the results obtained;

       (5) the time limitations imposed by the client or by the
       circumstances;
       (6) the nature and length of the professional relationship with the
       client;




                                    Page 11 of 18
       (7) the experience, reputation, and ability of the lawyer or lawyers
       performing the services; and

       (8) whether the fee is fixed or contingent on results obtained or
       uncertainty of collection before the legal services have been
       rendered.

Arthur Andersen & Co. v. Perry Equip. Corp., 945 S.W.2d 812, 818 (Tex.
1997)(citing TEX. DISCIPLINARY R. PROF. CONDUCT 1.04, reprinted in TEX. GOV’T
CODE, tit. 2, subtit. G app. (STATE BAR RULES, art. X, § 9). Evidence on each
factor is not required. Rapid Settlements, Ltd. v. Settlement Funding, LLC, 358
S.W.3d 777, 786 (Tex. App.—Houston [14th Dist.] 2012, no pet.); Arthur J.
Gallagher & Co. v. Dieterich, 270 S.W.3d 695, 706 (Tex. App.—Dallas 2008, no
pet.); State & Cnty. Mut. Fire Ins. Co. ex rel. So. United Gen. Agency of Tex. v.
Walker, 228 S.W.3d 404, 408 (Tex. App.—Fort Worth 2007, no pet.). Other
factors that can establish reasonableness include the entire record and the
common knowledge of the attorneys and judges. Rapid Settlements, 358 S.W.3d
at 786; Jarvis v. Rocanville Corp., 298 S.W.3d 305, 318 (Tex. App.—Dallas 2009,
pet. denied).

C. Proving Reasonable Fees
Reasonable attorneys’ fees may be calculated and proved using the lodestar
method. El Apple I, Ltd. v. Olivas, 370 S.W.3d 757, 760-61 (Tex. 2012). Lodestar
calculation involves two steps: (1) the court determines the reasonable number
of hours and a reasonable hourly rate and then (2) the number of hours is
multiplied by the applicable rate, the product being the lodestar fee. Id.
Lodestar proof requires evidence of: (1) the nature of the work; (2) who
performed the services and their rate; (3) approximately when the services were
performed; and (4) the number of hours worked. El Apple, 370 S.W.3d at 762-




                                     Page 12 of 18
64. This proof will almost always depend on corroboration by
contemporaneous billing records. Id. Trial courts are accorded considerable
deference in determining fees that are not excessive, redundant, or
unreasonable, and lodestar fees are presumptively reasonable. El Apple, 370
S.W.3d at 764-65.

The importance of billing records to support attorneys’ fee awards was again
stressed by the Texas Supreme Court in City of Laredo v. Montano, 414 S.W.3d
731 (Tex. 2013)(per curiam).

D. Challenging Fees
Whether segregation is required between claims that allow for a recovery of
attorney’s fees and claims that do not is a question of law. Clearview Properties,
L.P. v. Property Tex. SC One Corp., 287 S.W.3d 132, 143 (Tex. App.—Houston
[14th Dist.] 2009, pet. denied).

To avoid summary judgment on attorneys’ fees, a non-movant must do more
than just file a conclusory counter-affidavit criticizing the fees as unreasonable
and excessive. Basin Credit Consultants, Inc. v. Obregon, 2 S.W.3d 372, 373-74 (Tex.
App.—San Antonio 1999, pet. denied). In Obregon, the summary judgment
movant attached her counsel’s affidavit stating his experience and basis for his
opinion on the reasonableness of his attorney’s fees. Id. The non-movant then
tried to raise a fact issue by competing affidavit:

       The attorney’s fees alleged by Plaintiff ’s Motion for Summary
       Judgment are not reasonable and necessary for the sum sued
       upon. Attorney fees for Plaintiff should be less than $4,000.00.
       The hourly rate of $175.00 per hour is excessive by Plaintiff ’s
       attorney and should be $125.00 per hour. The number of hours




                                    Page 13 of 18
       to complete Plaintiff ’s attorneys services should be less than 30
       hours.

Id. at n.2. Because the counter-affidavit did not provide the affiant’s
qualifications or basis of his opinion as to what a reasonable fee might be, it
was held conclusory and insufficient. Id.

Similarly, in Cammack the Cook, LLC v. Eastburn, the summary judgment non-
movant’s affidavit did not raise a fact issue by merely complaining that “the
attorney’s fees plaintiff ’s attorney claims are not necessary or reasonable, and
they are an excessive and bad faith demand” without any challenge to the
number of hours expended, hourly rate, or necessity. 296 S.W.2d 884, 894-95
(Tex. App.—Texarkana 2009, pet. denied).

E. Schroeders’ Reasonable and Necessary Attorneys’ Fees
The trial court did not abuse its discretion in awarding Schroeder $63,787.95 in
attorneys’ fees and costs for successful oil and gas litigation that consumed
over 10 years to liberate 306.71 mineral acres of land. Schroeders’ attorneys’ fee
proof was sworn and documented by 11 pages of authenticated,
contemporaneous billing records describing every date of work, exact number
of incremental and total hours of the work (324 total hours), a substantive
description of the work, and the applicable rate for the work. (CR at 257-69)
The affidavit proof was unchallenged as to the preclusion of other work
imposed by this representation and the hourly rates charged. (CR at 288-89)
Lodestar fees, like Schroeders’, are presumptively reasonable.

Although the total amount of fees and costs was challenged by appellant
Stephens & Johnson Operating Co. (the only defendant liable for attorneys’
fees and costs), an appropriate fee was not suggested. The counter-affidavit



                                   Page 14 of 18
interposed legal conclusions (“legally sufficient evidence” and “equitable or
just”), made factual conclusions (“grossly disproportionate” and “excessive,
unreasonable”), and challenged the number of hours applicable to preparing
and prosecuting summary judgment motions—and not the underlying claims.
(CR at 288-89) Despite having access to each billing entry by date, amount, and
substantive description, appellant Stephens & Johnson Operating Co. did not
specifically object or request segregation for a single entry.

Appellees Schroeder’s attorneys’ fees proof adheres to the recent high hurdles
in El Apple and Montano set by the Texas Supreme Court over the last 2 years,
while appellant Stephens & Johnson Operating Co.’s does not clear the low
hurdle of Obregon set 16 years ago by this Appellate Court. The award of
attorneys’ fees and costs is further insulated from reversal by the deferential
abuse of discretion standard of review, and should be affirmed.

Prayer
Wherefore, Premises Considered, appellees respectfully request this Appellate
Court to affirm the trial court’s declaratory judgment as to the termination of
the subject oil and gas lease and the associated award of attorneys’ fees and
costs, and appellees further respectfully request any additional relief, both
general and special, at law or in equity, to which they may be justly entitled to
receive.




                                    Page 15 of 18
Respectfully submitted,




/s/ Baldemar Garcia Jr.
Baldemar Garcia Jr.
Texas Bar No. 00790740
email: bgarcia@personwhitworth.com
lead appellate counsel for appellees
Martha Cigarroa de Llano
Texas Bar No. 04250800
email: mdellano@personwhitworth.com
PWBM, LLP
602 East Calton Road, 2nd Floor (78041)
P. O. Drawer 6668 (78042)
Laredo, Texas
voice 956.727.4441
facsimile 956.727.2696



Certificate of compliance
According to the word count feature in Microsoft Word, this brief is 2,346
words, excluding the caption, identities of parties and counsel, statement
regarding oral argument, table of contents, index of authorities, statement of
the case, statement of issues presented, statement of jurisdiction, statement of
procedural history, signature, proof of service, certification, certificate of
compliance, and appendix. TEX. R. APP. P. 9.4.(i)(15,000 applicable word limit).




/s/ Baldemar Garcia Jr.




                                  Page 16 of 18
Certificate of service
Appellees’ brief was served by electronic mail on all counsel of record on
March 9, 2015. TEX. R. APP. P. 9.5.
Augustin Rivera Jr.
Dunn, Weathered, Coffey, Rivera, & Kasperitis, PC
611 South Upper Broadway
Corpus Christi, Texas 78401
facsimile 361.883.1599
email: ariverajr@swbell.net
Lynse L. Guerra
Skaggs & Guerra, LLP
710 Laurel
P. O. Drawer 2285
McAllen, Texas 78502
facsimile 956.630.6570
email: sgllp@sbcglobal.net




/s/ Baldemar Garcia Jr.
Baldemar Garcia Jr.




                                  Page 17 of 18
                              No. 04-14-00167-CV
                   Stephens & Johnson Operating Co., et al.,
                                 Appellants,
                                       vs.
                          Charles W. Schroeder, et al.,
                                  Appellees.



Appendix


1. Order granting summary judgment
2. Schroeder’s attorneys’ fees affidavit and attachments
3. Stephens & Johnson Operating Co. counter-affidavit




                                  Page 18 of 18
       FILED IN
4th COURT OF APPEALS
 SAN ANTONIO, TEXAS
03/9/2015 2:43:05 PM
  KEITH E. HOTTLE
        Clerk
       FILED IN
4th COURT OF APPEALS
 SAN ANTONIO, TEXAS
03/9/2015 2:43:05 PM
  KEITH E. HOTTLE
        Clerk
       FILED IN
4th COURT OF APPEALS
 SAN ANTONIO, TEXAS
03/9/2015 2:43:05 PM
  KEITH E. HOTTLE
        Clerk
