OPINION
MICHAEL MASSENGALE, Justice.
It is a cardinal rule of Texas summary-judgment practice that "[i]ssues not expressly presented to the trial court by written motion, answer or other response shall not be considered on appeal as grounds for reversal." TEX.R. CIV. P. 166a(c). "[T]he reasons for the summary judgment and the objections to it must be in writing and before the trial judge at the hearing." City of Houston v. Clear Creek Basin Auth.,
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