Robert ("Bob") Royal, and RR Royal Ranch Company, a Texas Corporation v. SAPH, LLC, a Texas Limited Liability Company, and Happy State Bank ( 2015 )

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ROBERT ROYAL AND RR ROYAL IN THE aIN
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RANCH COMPANY Or 2nd COURT OFé /
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FORT WORTH, TEXAS
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Plaintiffs, § ``
11/25/2015 2:58:08
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v. § 415 JUDICIAL DISTRI DEBRA SPISAK
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SAPH, LLC AND HAPPY STATE §
BANK §
Defendants. § OF PARKER COUNTY, TEXAS
NOTICE OF APPEAL
Plaintiffs, Robert Royal and RR Royal Ranch Company, parties to this case, file this
Notice of Appeal seeking to alter the trial court's judgment or other appealable order.
1. The trial court, trial court case number and style of this matter are shown in the
above caption.
2. The judgment or order appealed from was signed on October 26, 2015.
3. Robert Royal and RR Royal Ranch Company desire to appeal because (a)
Plaintiffs’ had to retain new legal counsel on short notice to properly defend Plaintiffs against
Defendants’ Motion for Final Summary Judgment, Motion for Sanctions, and Motion for
Protective Order and the trial court denied Plaintiffs’ Motion for Continuance to allow Plaintiffs’
counsel adequate time to prepare a defense; (b) Plaintiffs’ were prevented, through the trial
court’s sustaining of Defendants’ objections, from questioning Defendants’ witness in support of
Defendants’ Motion for Final Summary Judgment regarding ownership issues of the property
and creation of liens central to the present case; and (c) the award for sanctions was excessive.
4. This appeal is being taken to either the First or Fourteenth Court of Appeals.
5. This notice is being filed by Robert Royal and RR Royal Ranch Company.
NOTICE OF APPEAL Page I of 2
Respectfully submitted,
DORSETT JOHN ON & SWIFT, LLP
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J. C. Johnson
Texas Bar No 24067412
C. de Vild Jr.
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J. ,
Texas Bar No. 24065130
Robyn Trosper-Murrell
Texas Bar No. 24090441
mmfldcnsattjohnsommm
109 East Third Street, Suite 350
Fort Worth, Texas 76102
Telephone: (817) 900-8202
Facsimile: (817) 882-8526
ATTORNEYS FOR PLAINTIFFS
ROBERT ROYAL AND RR ROYAL RANCH
Pursuant to Texas Rules of Civil Procedure 21 and 21a, I certify that on November 25,
2015 a true and correct copy of Plaintiffs' Notice of Appeal was served to each person listed
below by the method indicated.
7
Michael Brinkley
BRINKLEY LAW PLLC
PO. Box 820711
Fort Worth, Texas 76182-0711
Stewart R. Werner
LAW OFFICES OF STEWART R. WERNER
801 S. Fillmore Street, Suite 720
Amarillo, Texas 79101
/
Attorneys for Defendants
C. J. de Vilder, Jr.
NOTICE OF APPEAL Page 2 of 2