ACCEPTED 01-15-00435-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 10/16/2015 6:31:36 PM CHRISTOPHER PRINE CLERK NO. 01-15-435-CV FILED IN 1st COURT OF APPEALS IN THE COURT OF APPEALS HOUSTON, TEXAS 10/16/2015 6:31:36 PM FIRST DISTRICT OF TEXAS, HOUSTON CHRISTOPHER A. PRINE Clerk

IRVING DROBNY, as representative of NAIU and NAIC, Appellant v. AMERICAN NATIONAL INSURANCE COMPANY, Appellee

APPELLEE’S BRIEF

Janet L. Rushing State Bar No. 17403100 Roni S. Mihaly State Bar No. 24027899 David J. Booth State Bar No. 24034333 Greer, Herz & Adams, L.L.P. 2525 South Shore Blvd., Suite 203 League City, Texas 77539 (409) 797-3204 (Phone) (281) 538-3791 (Fax)

ORAL ARGUMENT REQUESTED CERTIFICATE OF COMPLIANCE Pursuant to Texas Rule of Appellate Procedure 9.4, I certify that there are 6,930 words in this document, excepting those portions of the brief listed in Rule 9.4(i)(1), as calculated by the word count feature of Microsoft Word 2010, which was used to prepare this document.

/s/ Roni S. Mihaly Roni S. Mihaly

CERTIFICATE OF SERVICE This is to certify that on the 16th day of October, 2015, a copy of the foregoing document was served pursuant to the Texas Rule of Appellate Procedure 9.5 upon the following counsel: Via E-File and Commerical Delivery Service Ms. Savannah Robinson Law Offices of Savannah Robinson 1822 Main Danbury, Texas 77534 /s/ Roni S. Mihaly Roni S. Mihaly