Elsie O. Jones v. Jose G. Ramirez-Rodriguez ( 2015 )

June 23, 2015 June ll,h, 2015 Elsie O. Jones Appellant Jose G. Ramirez-Rodriguez Appellee RE: Court of Appeals Number: 03-14-00230-CV Trial Court Case Number: C-l-CV-13-002528 Jeffrey D. Kyle Clerk Third Court of Appeals Appellant/Plaintiff Elsie O. Jones asks the Court to reverse and render a judgment in favor of the Appellant Elsie O. Jones. STATEMENT OF THE CASE: Nature of the case: Appellant/Plaintiff sued the Appellee/ Defendant for recovery Property Damages (Negligence Per Se) (CLKRECP. 228-293) MOTION TO AMEND PETITION SPECIAL EXCEPTIONS, and for infringement of her Allotted disability parking space, and privileged; and for Parental Liability of defendant's children's in his household or parental liability for damages caused by their children's in his household, vandalism and intentional, malicious and Pain and Suffering; Mental anguish and willful acts of their minor children commit. Parent Neglect Named Child: Jose Alex Jimenez and violation with Texas Apartment Association Apartment lease law. Under the control and the care of the Defendant Jose G. Ramirez- Rodriguez. STATEMENT OF THE CASE: This appeal arises out of a take-nothing judgment rendered against Elsie 0. Jones and in favor of Jose G. Ramirez-Rodriguez. (Appellant's Tab 1). Jones filed a personal injury lawsuit for negligence against Rodriguez in connection with her allegation that Rodriguez' vehicle struck her parkedvehicle while leavingthe parking space next to hers. She also subsequently alleged that he negligently allowed children under his control to vandalize her parked vehicle. After Jones' Motion for New Trial was denied, she filed this appeal. (Appellant's Tabs 4 and 5). The Appellant/Plaintiff plea to jurisdiction asserting that the County Court at Law lacked jurisdiction because appellant/plaintiffsought damages greater than that of $250,000 or more. (Tex. Civ. Prac. &Rem. Code Ann 41.008 aWest 2008). Monetary relief over $200,000 but not more than $1,000,000. Appellant/Plaintiff Elsie 0. Jones should be awarded a judgment against the Appellee/Defendant Jose G. Ramirez-Rodriguez. r^RECEIVEDN JUN 1 2 Z015 THIRD COURT OF APPEALS \ JEFFREY D.KYtE / This is the relief sought, and including any alternative relief. Only this court can grant the relief requested. The Appellant/Plaintiff Elsie 0. Jones asks the Court to reverse the trial court and remand the cause for a new trial based on either the factual-sufficiency issue, or In the alternative, Appellant/ Plaintiff Elsie 0. Jones asks the court to reverse and render or modify the judgment and to award the Appellant/ Plaintiff Elsie 0. Jones is entitled. ectfuHy Submitted, PRO SE PLAINTIFF ELSIE O.JONES 2347 DOUGLAS STREET #6106 AUSTIN, TEXAS 78741 (512) 809-7698 EMAIL ADDRESS: kevinandelsiejones@yahoo.com PROSE FOR APPELLANT ELSIE 0. JONES APPELLANT I hereby certify that a true and correct copy of the foregoing instrument was served on the counsel of records in this appeal in with the Texas Rules of Civil and Appellant Procedure by certified mail and return receipt requested, on the 12th, day of June, 2015 as follow. FREY, NAVARRO & WHORTON, P.L.L.C. MS, MONICA JO QUINENE AUGUON Texas Bar No. 24073827 Address: Trinity Plaza I, Suite 550 750 E. Mulberry Avenue San Antonio, Texas 78212 Telephone: (210) 732-9800 Fax: (210) 568-6871 Email Address: monica(5)fnwlawfirm.com ATTORNEYS FOR APPELLEE JOSE G. RAMIREZ-RODIGUEZ APPELLEE PRO SE APPELLANT ELSIE O. JONES Court of Appeals Number: 03-14-00230-CV Trial Court Case Number: C-l-CV-13-002528 ELSIE O.JONES Certificate of Compliance As required by Texas Rule ofAppellate Procedure 52.10(a), Icertify that Ihave notified or made adiligent effort to notify all parties by expedited means such as by email address which is listed in the court file for the counsel on record that this motion for leave to file appellant's reply briefwill befiled. Icertify that this document contains 663 words, as indicated by the word count function of the computer program used to prepared it, and certificate of conference and Motion for leave to file Appellant's Reply Briefas provided by Appellant Rule 9.4(f). dBtfffi.J:fc PRO SE LITIGANT ELSIE 0. JONES 2347 DOUGLAS STREET #6106 AUSTIN, TEXAS 78741 TELEPHONE: (512) 809-7698 EMAIL ADDRESS: kevinandelsieiones@vahoo.com June 18th, 2015. [Date] JUNE 18™, 2015