Kevin Tower v. Bank of America, N.A.

Opinion

ACCEPTED 03-14-00404-CV 7194568 THIRD COURT OF APPEALS AUSTIN, TEXAS 10/1/2015 4:29:17 PM JEFFREY D. KYLE CLERK No. 03-14-00404-CV

In the Third Court of Appeals FILED IN 3rd COURT OF APPEALS Austin, Texas AUSTIN, TEXAS 10/1/2015 4:29:17 PM JEFFREY D. KYLE Clerk KEVIN TOWER AND KARRIE LYNN TOWER Appellants, V. BANK OF AMERICA, N.A. Appellee.

ON APPEAL FROM THE COUNTY COURT AT LAW, HAYS COUNTY, TEXAS CAUSE NO. 13-0320-C

APPELLEE’S RESPONSE TO MOTION FOR REHEARING

Jonathan M. Williams jwilliams@mlg-defaultlaw.com State Bar No. 00791932 MARINOSCI & BAXTER MARINOSCI LAW GROUP, P.C. 14643 Dallas Parkway, Suite 750 Dallas, Texas 75245 Phone: (972) 331-2100 Fax: (972) 331-5240

ATTORNEYS FOR APPELLEE BANK OF AMERICA, N.A.

PAGE 1 RESPONSE TO MOTION FOR REHEARING Appellee files this brief and initial response to Appellants’ Motion for

Rehearing to bring to the Court’s attention that Appellants have not served any

document filed during the pendency of this appeal upon the Appellee and that all

certifications of service by facsimile are not accurate.

Appellee has previously contacted the Appellants at the beginning of the

appeal, by phone, regarding this matter without any response. The only notice that

Appellee has ever received was from the Court.

CONCLUSION AND PRAYER

Appellee therefore respectfully requests that this Court deny Appellants’

Motion for Rehearing.

Respectfully Submitted,

/s/ Jonathan M. Williams jwilliams@mlg-efaultlaw.com State Bar No. 00791932 MARINOSCI & BAXTER MARINOSCI LAW GROUP, P.C. 14643 Dallas Parkway, Suite 750 Dallas, Texas 75245 Phone: (972) 331-2100 Fax: (972) 331-5240

PAGE 2 CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing Response to Motion for Rehearing was served via the following method to the following persons on the 1stth day of October 2015.

Kevin Tower Via first class mail and 541 Bayou Bend CMRRR# 9407 1118 9956 3833 9527 82 Buda, Texas 78610

Karrie Lynn Tower Via first class mail and 541 Bayou Bend CMRRR# 9407 1118 99556 3833 9576 40 Buda, Texas 78610

/s/ Jonathan M. Williams Jonathan M. Williams

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