Donna Kohlhausen, as Independent of the Estate of Valleyssa Joste Cerra v. Brian Keith Baxendale, as Independent of the Estate of Kelley William Joste AKA William Kelley Joste

Court of Appeals of Texas·Decided November 10, 2015·No. 01-15-00901-CV·Published

Opinion

ACCEPTED 01-15-00901-CV DV PROBATE COURT 2 FIRST COURT OF FILED APPEALS 10/21/2015 10:23:00 AM HOUSTON, TEXAS Stan 3:20:58 11/10/2015 Stanart PM County Clerk CHRISTOPHER PRINE Harris County CLERK

Cause No. 295986-401

DONNA KOHLHAUSEN, as § IN THE PROBATE COURT FILED IN Independent Executor of the Estate of § 1st COURT OF APPEALS Valleyssa Joste Cerra, § HOUSTON, TEXAS Plaintiff, § 11/10/2015 3:20:58 PM § CHRISTOPHER A. PRINE v. § ClerkNo. 2 § BRIAN KEITH BAXENDALE, as § Independent Executor of the Estate of § Kelley William Joste aka William Kelley § Joste, § Defendant. § OF HARRIS COUNTY, TEXAS §

NOTICE OF APPEAL

Plaintiff Donna Kohlhausen, as Independent Executor of the Estate of Valleyssa Joste

Cerra (“Plaintiff”) appeals from the probate court’s order granting Defendant Brian Keith

Baxendale, as Independent Executor of the Estate of Kelley William Joste’s motion for

summary judgment signed on August 11, 2015, the probate court’s order denying Plaintiff’s

motion for reconsideration signed on October 6, 2015, and all adverse interlocutory rulings

that merged into the judgment. Plaintiff takes this appeal to either the First or Fourteenth Court

of Appeals.

Plaintiff respectfully asks the trial clerk to send a copy of this notice of appeal

immediately to the appellate court clerk and to the court reporter responsible for preparing the

reporter’s record.

1 Respectfully submitted,

JOHNS MARRS ELLIS & HODGE LLP

/s/ Joseph R. Marrs Joseph R. Marrs State Bar No. 24037029 jmarrs@jmehlaw.com Leah K. Lanier State Bar No. 24080068 llanier@jmehlaw.com 500 Dallas Street, Suite 1350 Houston, Texas 77002 (713) 609-9503 (713) 583-5825 fax

Attorneys for Plaintiff Donna Kohlhausen, as Independent Executor of the Estate of Valleyssa Joste Cerra, Plaintiff

2 CERTIFICATE OF SERVICE

This is to certify that on October 21, 2015, a true and correct copy of the foregoing was sent to the following:

James H. Stilwell Via E-Service 1400 Woodloch Forest Drive, Ste. 590 The Woodlands, TX 77380 (281) 419-6200

/s/ Joseph R. Marrs Joseph R. Marrs

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ACCEPTED 01-15-00901-CV DV PROBATE COURT 2 FIRST COURT OF FILED APPEALS 10/21/2015 10:23:00 AM HOUSTON, TEXAS Stan 3:20:58 11/10/2015 Stanart PM County Clerk CHRISTOPHER PRINE Harris County CLERK

Cause No. 295986-401

NOTICE OF APPEAL

Plaintiff Donna Kohlhausen, as Independent Executor of the Estate of Valleyssa Joste

Cerra (“Plaintiff”) appeals from the probate court’s order granting Defendant Brian Keith

Baxendale, as Independent Executor of the Estate of Kelley William Joste’s motion for

summary judgment signed on August 11, 2015, the probate court’s order denying Plaintiff’s

motion for reconsideration signed on October 6, 2015, and all adverse interlocutory rulings

that merged into the judgment. Plaintiff takes this appeal to either the First or Fourteenth Court

of Appeals.

Plaintiff respectfully asks the trial clerk to send a copy of this notice of appeal

immediately to the appellate court clerk and to the court reporter responsible for preparing the

reporter’s record.

1 Respectfully submitted,

JOHNS MARRS ELLIS & HODGE LLP

Attorneys for Plaintiff Donna Kohlhausen, as Independent Executor of the Estate of Valleyssa Joste Cerra, Plaintiff

2 CERTIFICATE OF SERVICE

This is to certify that on October 21, 2015, a true and correct copy of the foregoing was sent to the following:

James H. Stilwell Via E-Service 1400 Woodloch Forest Drive, Ste. 590 The Woodlands, TX 77380 (281) 419-6200

/s/ Joseph R. Marrs Joseph R. Marrs

Donna Kohlhausen, as Independent of the Estate of Valleyssa Joste Cerra v. Brian Keith Baxendale, as Independent of the Estate of Kelley William Joste AKA William Kelley Joste, (Tex. Ct. App. 2015).

Pincite

Donna Kohlhausen, as Independent of the Estate of Valleyssa Joste Cerra v. Brian Keith Baxendale, as Independent of the Estate of Kelley William Joste AKA William Kelley Joste (Donna Kohlhausen, as Independent of the Estate of Valleyssa Joste Cerra v. Brian Keith Baxendale, as Independent of the Estate of Kelley William Joste AKA William Kelley Joste) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.