in Re Jessica Bachelor

Opinion

ACCEPTED 01-15-00287-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 4/1/2015 9:59:15 AM CHRISTOPHER PRINE CLERK NO. 01-15-00287-CV

FILED IN IN THE 1st COURT OF APPEALS HOUSTON, TEXAS 4/1/2015 9:59:15 AM FIRST COURT OF APPEALS CHRISTOPHER A. PRINE Clerk HOUSTON, TEXAS

JESSICA BACHELOR RELATOR

v. ERIC BACHELOR REAL PARTY IN INTEREST

RELATOR'S MOTION FOR TEMPORARY RELIEF

Stephen Lekas TX Bar# 12188400 6001 Clinton Dr. Houston, TX 77020 Tel#: (713) 671-9494 Fax#: (713) 671-9496 NO. 01-15-00287-CV

IN THE FIRST COURT OF APPEALS HOUSTON, TEXAS

In Re Jessica Bachelor

Original Proceeding From the 309th Judicial District Court of Harris County, Texas

MOTION FOR EMERGENCY RELIEF

TO THE HONORABLE FIRST, COURT OF APPEALS:

Pursuant to Texas Rule of Appellate Procedure 52.10, Jessica Bachelor, Relator, files this Motion for Emergency Relief to accompany her Petition for Writ of Mandamus and in support of this motion would show the court as follows: This Motion for Temporary Relief is brought by Relator, Jessica Bachelor, who shows in support: I. Jessica Bachelor filed her Petition for Writ of Mandamus on 3-27-2015 Nicolette Milton certifies that on 3-28-2015, she notified Real Party in Interest, Eric Bachelor by registered mail that a Motion for Temporary relief would be filed. Tex. R. App. P. 52.10(a). II. The Court may grant temporary relief pending its determination of an original proceeding. Tex. R. App. P. 52.10(b). This emergency stay is necessary to preserve jurisdiction in the Trial Court, and the status quo. Furthermore, immediate relief is requested in the event that Court grants Relator's Motion. See In re Reed, 901 S.W.2d 604, 609 (Tex. App. - San Antonio 1995)(orig. Proceeding). Prayer Jessica Bachelor, prays that the Court grant her motion for temporary relief to maintain the status quo of the parties and to preserve the Court's jurisdiction to consider the merits of Relator's Petition for Writ of Mandamus.

STEPHEN LEKAS ATTORNEY FOR RELATOR 6001 Clinton Drive Houston, Texas 77020 (713) 671-9494 (713) 671-9496 (fax) TBA#12188400

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the Motion for Temporary

Relief was faxed to the opposing counsel and hand delivered to the trial judge on

4-1-2015. CERTIFICATE OF CONFERENCE

All parties have been notified as of3-28-2015 and have not responded to

Relator's request for agreement.

Real Party in Interest via CMRR

Matthew Skillern Attorney at Law 701 N. Post Oak, S-207 Houston, TX 77024 Tel: (713)229-8855 Fax: (713) 481-8800 TB# 24041926

Trial Court Judge via hand delivery

Hon. Charley Prine 246th Judicial District Court 20 1 Caroline Houston, TX 77002 Tel: t I '3 1 $ 5""' 13 ~