the City of Friendswood and Kevin Holland v. Paul and Carolyn Horn, Mike and Lucy Stacy, Pete and Judy Garcia and Janice Frankie

Court of Appeals of Texas·Decided May 13, 2015·No. 01-15-00436-CV·Published

Opinion

ACCEPTED

Filed: 5/8/201501-15-00436-CV 4:13:47 PM

JOHN FIRST COURT

D. KINARD OF APPEALS - District Clerk

Galveston HOUSTON, TEXAS County, Texas

5/13/2015

Envelope No.11:53:36

5218148AM

CHRISTOPHER PRINE

By: Shailja Dixit

5/8/2015 4:17:22CLERK

PM

CAUSE NO. 14CV0490

PAUL AND CAROLYN HORN, MIKE § IN THE DISTRICT COURT FILED IN OF

AND LUCY STACY, PETE AND JUDY § 1st COURT OF APPEALS HOUSTON, TEXAS

GARCIA AND JANICE FRANKIE § § GALVESTON5/13/2015 COUNTY, 11:53:36 AM

TEXAS

CHRISTOPHER A. PRINE

v. § Clerk §

CITY OF FRIENDSWOOD and § MAYOR KEVIN M. HOLLAND § 212TH JUDICIAL DISTRICT

DEFENDANTS’ NOTICE OF APPEAL

The City of Friendswood and Kevin Holland, Defendants in the above numbered

matter, file this Notice of Interlocutory Appeal pursuant to § 51.014(a)(8) and §

51.014(a)(5) of the Texas Civil Practice and Remedies Code, and desire to appeal the

District Court's April 20, 2015 Order denying Defendants’ Plea to the Jurisdiction and

Defendants’ Motion to Dismiss.

This is an accelerated appeal which will be taken to the 1st or 14th Court of

Appeals.

Respectfully submitted,

CHAMBERLAIN, HRDLICKA WHITE WILLIAMS & AUGHTRY

/s/William S. Helfand WILLIAM S. HELFAND SBOT # 09388250 CHARLES T. JEREMIAH SBOT # 00784338 1200 Smith Street, Suite1400 Houston, Texas 77002 (713) 654-9630 (713) 658-2553 Bill.helfand@chamberlainlaw.com Charles.jeremiah@chamberlainlaw.com

ATTORNEYS FOR DEFENDANT, CITY OF FRIENDSWOOD, TEXAS

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing was forwarded in accordance with the local rules, via facsimile, hand-delivery, and/or certified mail, return receipt requested, on this 8th day of May, 2015 to the following:

Aaron Pool James T. Sunosky Donato Minx Brown & Pool, PC 3200 Southwest Freeway, Suite 2300 Houston, Texas 77027

/s/ William S. Helfand

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the City of Friendswood and Kevin Holland v. Paul and Carolyn Horn, Mike and Lucy Stacy, Pete and Judy Garcia and Janice Frankie, (Tex. Ct. App. 2015).

the City of Friendswood and Kevin Holland v. Paul and Carolyn Horn, Mike and Lucy Stacy, Pete and Judy Garcia and Janice Frankie (the City of Friendswood and Kevin Holland v. Paul and Carolyn Horn, Mike and Lucy Stacy, Pete and Judy Garcia and Janice Frankie) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.