Johnny Partain v. State of Texas

Opinion

ACCEPTED 1/27/2025 2:44 PM 15-25-00005-CV FIFTEENTH COURT OF Velva APPEALSL. Price District AUSTIN, TEXAS Clerk Travis County 1/29/2025 1:09 PM CAUSE NO. D-1-GN-24-002560 D-1-GN-24-002560 CHRISTOPHER A.Rosa PRINEOneal CLERK STATE OF TEXAS § IN THE DISTRICT COURT Plaintiffs § FILED IN 15th COURT OF APPEALS § AUSTIN, TEXAS § 126TH JUDICIAL DISTRICT 1/29/2025 1:09:48 PM v. § CHRISTOPHER A. PRINE § Clerk JOHNNY PARTAIN § TRAVIS COUNTY, TEXAS Defendant § _____________________________________________________________________

DEFENDANT’S NOTICE OF APPEAL

COMES NOW Defendant, Johnny Partain, filing this notice and hereby giving his notice of appeal of Order Granting Permanent Injunction And Other Relief signed on December 19, 2024, in the above styled and numbered District Court cause, and stating his desire to appeal said order. This appeal is taken to the 3rd Court of Appeals or to the 15th Court of Appeals on basis of a constitutionality and jurisdictional challenges implicating the State of Texas. Defendant shall request the Appeals Court to accelerate this appeal due to this aforementioned order placing the State of Texas in violation of Amendments 4, 5, 9, and 14 of the United States Constitution and Art. 1, Sec. 3, 9, 13, 17, and 29 of the Texas Constitution, causing irreparable damage on the Defendant, wherein the State consistently gives itself immunity, foreclosing any judicial remedy.

Respectfully submitted,

________________________ JOHNNY PARTAIN 7020 N. 16th Street McAllen, Texas 78504 956-687-4966

1 CERTIFICATE OF SERVICE This certifies that a true and correct copy of the foregoing document as been serviced by email on this January 27, 2025 to the following:

ALI THORBURN Assistant Attorney General General Litigation Division Texas Bar No. 24125064 Ali.Thorburn@oag.texas.gov

___________________________ Johnny Partain 7020 N 16th Street McAllen, Texas 78504 partain@atlastechnologies.biz 956-240-1821

2 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: 96640390 Filing Code Description: Notice of Appeal Filing Description: DEFENDANT’S NOTICE OF APPEAL Status as of 1/28/2025 9:01 AM CST

Associated Case Party: STATE OF TEXAS

Name BarNumber Email TimestampSubmitted Status

Ali Thorburn 24125064 ali.thorburn@oag.texas.gov 1/27/2025 2:44:20 PM SENT

Zachary Rhines Zachary.Rhines@oag.texas.gov 1/27/2025 2:44:20 PM SENT

Associated Case Party: JOHNNY PARTAIN

Johnny Partain partain@atlastechnologies.biz 1/27/2025 2:44:20 PM SENT

Case Contacts

Ariana Ines ariana.ines@oag.texas.gov 1/27/2025 2:44:20 PM SENT