ACCEPTED 15-25-00227-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 12/9/2025 1:24 AM CHRISTOPHER A. PRINE CLERK FILED IN IN THE FIFTEENTH COURT OF APPEALS 15th COURT OF APPEALS AUSTIN, TEXAS AT AUSTIN, TEXAS 12/9/2025 1:24:20 AM CHRISTOPHER A. PRINE Clerk
Case No. 15-25-00227 - CV (Transferred from the Third Court of Appeals)
IN RE CEDRIC M. SCOTT, PhD Relator, Pro Se
v.
GENERAL LAND OFFICE OF THE STATE OF TEXAS Real Party of Interest
Original Proceeding from the 250th Judicial District Court of Travis County, Texas Trial Court Cause No. D-1-GN-25-000006
RELATOR’S MOTION FOR EMERGENCY RELIEF TO THE HONORABLE FIFTEENTH COURT OF APPEALS:
Relator, Cedric M. Scott, PhD1, respectfully requests this Court for
emergency temporary relief under Texas Rule of Appellate Procedure 52.10 to
preserve her rights and prevent irreparable harm while the Court considers her
Petition for Writ of Mandamus filed December 5, 2025 and accepted for filing on
December 8, 2025.
Emergency intervention is necessary because the orders issued by former
presiding Judge Cory R. Liu—including orders compelling Relator’s deposition,
denying dispositive motions, and affecting the procedural posture of the case—
were issued while Judge Liu was constitutionally disqualified from the onset this
whistleblower case. As such, the orders are void ab initio, and enforcement of
them would inflict additional irreparable harm on Relator, who currently has no
successor trial judge available to correct or vacate the void orders.
I. RELIEF REQUESTED
Under TRAP 52.10, Relator respectfully requests that this Court:
1. Stay enforcement of all orders issued by Judge Cory R. Liu in Cause No. D-1-GN-25-000006, including but not limited to:
• The order compelling Relator to appear for deposition,
1 Plaintiff’s first name is pronounced See-Drick and not Said-Drick. Gender is female, and pronouns are she, her, and hers.
2 • The order setting hearings on motions,
• The denial of Relator’s dispositive motions, and
• Any procedural directives affecting Relator’s rights.
2. Preserve the status quo by prohibiting GLO or its counsel from attempting
to enforce or rely upon the void orders pending this Court’s final resolution
of the mandamus.
3. Order the Real Party in Interest not conduct any deposition, hearing,
conference, or other litigation activity based on orders issued by Judge Liu
while disqualified.
4. Grant any further emergency relief necessary to protect the Court’s
jurisdiction and prevent further irreparable harm.
II. EMERGENCY RELIEF IS NECESSARY TO PREVENT IRREPARABLE HARM
Emergency relief is appropriate where temporary orders are needed to
protect the Court’s jurisdiction or prevent harm that cannot be remedied on
appeal. Tex. R. App. P. 52.10(a).
A. Enforcement of Void Orders Constitutes Irreparable Harm
Under Tex. Const. art. V, § 11, a judge who previously represented a party is
constitutionally disqualified. Orders issued during disqualification are:
• Void,
3 • Unenforceable, and
• Subject to mandamus relief.
See Buckholts I.S.D. v. Glaser, 632 S.W.2d 146, 148–49 (Tex. 1982).
Requiring Relator to comply with void orders—especially a compelled
deposition order—would inflict harm that cannot be cured through appellate
review, satisfying the standard for temporary relief.
B. Relator Has No Functional Trial Court
Judge Liu recused himself on November 21, 2025, and as of this filing:
• No successor judge has been appointed,
• Void orders remain unaddressed, and
• The trial court is unable to act.
Relator thus has no avenue to seek relief in the trial court, satisfying the
requirement that emergency intervention is necessary to preserve her rights.
C. Continued Delay Compounds Professional and Financial Harm
Relator has been without comparable employment since December 3, 2024
and continues to experience ongoing blacklisting. Every additional week of
litigation paralysis:
• Compounds economic loss,
• Delays relief under the Texas Whistleblower Act, and
• Worsens the prejudice caused by void orders and procedural breakdown.
4 The Texas Supreme Court recognizes that where “delay will permanently
prejudice the rights of the parties,” emergency relief may be warranted. In re
McAllen Med. Ctr., 275 S.W.3d 458, 466 (Tex. 2008).
III. EMERGENCY RELIEF IS NECESSARY TO PRESERVE THE COURT’S JURISDICTION
If the Court does not issue a temporary stay, GLO may attempt to:
• Enforce the void deposition order,
• Continue litigation activity without judicial authority,
• Take actions premised on void rulings, or
• Create additional procedural complications that frustrate appellate
review.
Issuing temporary relief under TRAP 52.10 prevents the Real Party from
relying on void orders in a manner that could moot or undermine the mandamus.
IV. REQUEST FOR TEMPORARY RELIEF WITHOUT PRIOR NOTICE
Under Texas Rule of Appellate Procedure 52.10(b), the Court may grant
temporary relief without prior notice where immediate intervention is necessary
to prevent irreparable injury or to protect the Court’s jurisdiction. This is such a
case. Relator respectfully submits that emergency relief without prior notice is
warranted because:
5 1. There is currently no successor judge to whom Relator can apply for
vacatur of the void orders. Since Judge Liu’s recusal on November 21, 2025,
the trial court has been unable to act, leaving Relator without any avenue for
relief at the trial-court level.
2. All operative orders were issued by a constitutionally disqualified judge,
rendering them void ab initio. Enforcement of void orders constitutes
immediate and irreparable harm that cannot be remedied on appeal.
3. The compelled deposition order presents imminent harm because GLO
intends to enforce a deposition, notwithstanding Judge Liu’s disqualification
and the absence of judicial oversight. Requiring Relator to comply with a
void deposition order would undermine the integrity of the judicial process
and prejudice the mandamus proceeding itself.
4. The Real Party in Interest continues to benefit from procedural paralysis,
while Relator continues to suffer ongoing blacklisting, loss of comparable
employment, and increasing prejudice with each week of delay.
5. Temporary relief is necessary to preserve the status quo so that the Court
may fully and fairly exercise its jurisdiction over the pending mandamus
petition. Without a stay, the Real Party may take actions—such as attempting
to enforce void orders or conduct discovery—that would create procedural
complications or moot portions of the mandamus before this Court can rule.
6 Because the harm is ongoing, immediate, and cannot be corrected later,
Relator respectfully requests that the Court issue temporary relief without awaiting
a response, as permitted by TRAP 52.10(b). Given the imminent risk of irreparable
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ACCEPTED 15-25-00227-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 12/9/2025 1:24 AM CHRISTOPHER A. PRINE CLERK FILED IN IN THE FIFTEENTH COURT OF APPEALS 15th COURT OF APPEALS AUSTIN, TEXAS AT AUSTIN, TEXAS 12/9/2025 1:24:20 AM CHRISTOPHER A. PRINE Clerk
Case No. 15-25-00227 - CV (Transferred from the Third Court of Appeals)
IN RE CEDRIC M. SCOTT, PhD Relator, Pro Se
v.
GENERAL LAND OFFICE OF THE STATE OF TEXAS Real Party of Interest
Original Proceeding from the 250th Judicial District Court of Travis County, Texas Trial Court Cause No. D-1-GN-25-000006
RELATOR’S MOTION FOR EMERGENCY RELIEF TO THE HONORABLE FIFTEENTH COURT OF APPEALS:
Relator, Cedric M. Scott, PhD1, respectfully requests this Court for
emergency temporary relief under Texas Rule of Appellate Procedure 52.10 to
preserve her rights and prevent irreparable harm while the Court considers her
Petition for Writ of Mandamus filed December 5, 2025 and accepted for filing on
December 8, 2025.
Emergency intervention is necessary because the orders issued by former
presiding Judge Cory R. Liu—including orders compelling Relator’s deposition,
denying dispositive motions, and affecting the procedural posture of the case—
were issued while Judge Liu was constitutionally disqualified from the onset this
whistleblower case. As such, the orders are void ab initio, and enforcement of
them would inflict additional irreparable harm on Relator, who currently has no
successor trial judge available to correct or vacate the void orders.
I. RELIEF REQUESTED
Under TRAP 52.10, Relator respectfully requests that this Court:
1. Stay enforcement of all orders issued by Judge Cory R. Liu in Cause No. D-1-GN-25-000006, including but not limited to:
• The order compelling Relator to appear for deposition,
1 Plaintiff’s first name is pronounced See-Drick and not Said-Drick. Gender is female, and pronouns are she, her, and hers.
2 • The order setting hearings on motions,
• The denial of Relator’s dispositive motions, and
• Any procedural directives affecting Relator’s rights.
2. Preserve the status quo by prohibiting GLO or its counsel from attempting
to enforce or rely upon the void orders pending this Court’s final resolution
of the mandamus.
3. Order the Real Party in Interest not conduct any deposition, hearing,
conference, or other litigation activity based on orders issued by Judge Liu
while disqualified.
4. Grant any further emergency relief necessary to protect the Court’s
jurisdiction and prevent further irreparable harm.
II. EMERGENCY RELIEF IS NECESSARY TO PREVENT IRREPARABLE HARM
Emergency relief is appropriate where temporary orders are needed to
protect the Court’s jurisdiction or prevent harm that cannot be remedied on
appeal. Tex. R. App. P. 52.10(a).
A. Enforcement of Void Orders Constitutes Irreparable Harm
Under Tex. Const. art. V, § 11, a judge who previously represented a party is
constitutionally disqualified. Orders issued during disqualification are:
• Void,
3 • Unenforceable, and
• Subject to mandamus relief.
See Buckholts I.S.D. v. Glaser, 632 S.W.2d 146, 148–49 (Tex. 1982).
Requiring Relator to comply with void orders—especially a compelled
deposition order—would inflict harm that cannot be cured through appellate
review, satisfying the standard for temporary relief.
B. Relator Has No Functional Trial Court
Judge Liu recused himself on November 21, 2025, and as of this filing:
• No successor judge has been appointed,
• Void orders remain unaddressed, and
• The trial court is unable to act.
Relator thus has no avenue to seek relief in the trial court, satisfying the
requirement that emergency intervention is necessary to preserve her rights.
C. Continued Delay Compounds Professional and Financial Harm
Relator has been without comparable employment since December 3, 2024
and continues to experience ongoing blacklisting. Every additional week of
litigation paralysis:
• Compounds economic loss,
• Delays relief under the Texas Whistleblower Act, and
• Worsens the prejudice caused by void orders and procedural breakdown.
4 The Texas Supreme Court recognizes that where “delay will permanently
prejudice the rights of the parties,” emergency relief may be warranted. In re
McAllen Med. Ctr., 275 S.W.3d 458, 466 (Tex. 2008).
III. EMERGENCY RELIEF IS NECESSARY TO PRESERVE THE COURT’S JURISDICTION
If the Court does not issue a temporary stay, GLO may attempt to:
• Enforce the void deposition order,
• Continue litigation activity without judicial authority,
• Take actions premised on void rulings, or
• Create additional procedural complications that frustrate appellate
review.
Issuing temporary relief under TRAP 52.10 prevents the Real Party from
relying on void orders in a manner that could moot or undermine the mandamus.
IV. REQUEST FOR TEMPORARY RELIEF WITHOUT PRIOR NOTICE
Under Texas Rule of Appellate Procedure 52.10(b), the Court may grant
temporary relief without prior notice where immediate intervention is necessary
to prevent irreparable injury or to protect the Court’s jurisdiction. This is such a
case. Relator respectfully submits that emergency relief without prior notice is
warranted because:
5 1. There is currently no successor judge to whom Relator can apply for
vacatur of the void orders. Since Judge Liu’s recusal on November 21, 2025,
the trial court has been unable to act, leaving Relator without any avenue for
relief at the trial-court level.
2. All operative orders were issued by a constitutionally disqualified judge,
rendering them void ab initio. Enforcement of void orders constitutes
immediate and irreparable harm that cannot be remedied on appeal.
3. The compelled deposition order presents imminent harm because GLO
intends to enforce a deposition, notwithstanding Judge Liu’s disqualification
and the absence of judicial oversight. Requiring Relator to comply with a
void deposition order would undermine the integrity of the judicial process
and prejudice the mandamus proceeding itself.
4. The Real Party in Interest continues to benefit from procedural paralysis,
while Relator continues to suffer ongoing blacklisting, loss of comparable
employment, and increasing prejudice with each week of delay.
5. Temporary relief is necessary to preserve the status quo so that the Court
may fully and fairly exercise its jurisdiction over the pending mandamus
petition. Without a stay, the Real Party may take actions—such as attempting
to enforce void orders or conduct discovery—that would create procedural
complications or moot portions of the mandamus before this Court can rule.
6 Because the harm is ongoing, immediate, and cannot be corrected later,
Relator respectfully requests that the Court issue temporary relief without awaiting
a response, as permitted by TRAP 52.10(b). Given the imminent risk of irreparable
harm, Relator requests immediate temporary relief under TRAP 52.10(b). Should
the Court prefer to request a response, Relator defers to the Court’s discretion.
V. PRAYER
Relator respectfully requests that the Court grant this Motion for Emergency
Relief under TRAP 52.10 and:
1. Stay all orders issued by Judge Cory R. Liu in the underlying case;
2. Prohibit enforcement or reliance upon those orders pending mandamus
review;
3. Preserve the status quo by preventing GLO from compelling Relator’s
deposition or engaging in litigation activity based on void orders; and
4. Grant all further relief to which Relator is entitled.
Respectfully submitted,
/s/ Cedric M. Scott
Cedric M. Scott, PhD Relator, Pro Se Email: cedricscott41@gmail.com
Date: December 9, 2025
7 CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing Relator’s Motion for
Emergency Relief was served in accordance with Texas Rule of Appellate
Procedure 9.5, on December 9, 2025 by electronic service (e-Filing) to the
following:
Real Party in Interest Counsel
Sara Labashosky State Bar No. 24129467 slabashosky@bickerstaff.com
Gunnar P. Seaquist State Bar No. 24043358 gseaquist@bickerstaff.com
Bickerstaff Heath Delgado Acosta LLP 3711 S. MoPac Expressway Building One, Suite 300 Austin, Texas 78746 (512) 472-8021
Respondent The Honorable Cory R. Liu Judge of the 250th Judicial District Court (Recused in Trial Court Cause No. D-1-GN-25-000006) Travis County, Texas Email: 250.Submission@traviscountytx.gov
/s/ Cedric M. Scott Cedric M. Scott, PhD Relator, Pro Se
8 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.
Envelope ID: 108866059 Filing Code Description: Motion - Exempt Filing Description: Relator's Motion for Emergency Relief Status as of 12/9/2025 7:26 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Honorable Cory R.Liu 250.submission@traviscountytx.gov 12/9/2025 1:24:20 AM SENT
Jeffrey Moore jmoore@bickerstaff.com 12/9/2025 1:24:20 AM SENT
Sara Labashosky slabashosky@bickerstaff.com 12/9/2025 1:24:20 AM SENT
Gunnar Seaquist gseaquist@bickerstaff.com 12/9/2025 1:24:20 AM SENT