in the Interest of C.Y.K.S., a Child ( 2015 )

ACCEPTED
2001-61475
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
6/29/2015 5:00:23 PM
CHRISTOPHER PRINE
CLERK
CAUSE NO. 2001-61475
FILED IN
IN THE INTEREST OF § IN THE DISTRICT COURT
14th COURT OF APPEALS
§ HOUSTON, TEXAS
§ 6/29/2015 5:00:23 PM
§ CHRISTOPHER A. PRINE
CHRISTIAN YVONNE KOZMO § OF HARRIS COUNTY, Clerk
TEXAS
SPATES §
§
§
CHILD § 247th/312th JUDICIAL DISTRICT
NOTICE OF APPEAL
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Christopher Spates on this 29th day of June 2015, appearing by and
through the undersigned counsel of record, and pursuant to the authority of Rule 25 of the
Texas Rules of Appellate Procedure, filing this Notice of Appeal. In support thereof,
Christopher Spates would show the Court the following:
1. Christopher Spates desires to appeal to either the First or Fourteenth Court of Appeals,
the Final Order entered in Cause No. 2001-61475; In The Interest of Christian Yvonne Kozmo
Spates, which was signed by the Presiding Judge of the 312th Judicial District Court of Harris
County, Texas on May 28, 2015.
2. Christopher Spates files this appeal because he is directly and adversely affected by the
Final Order.
3. Appellant seeks to render void and unenforceable, the trial court’s order of May 28, 2015,
which set aside the order of February 13, 2015 modifying child support.
4. The trial court signed the Final Order on May 28, 2015, thereby making the deadline to
file a notice of appeal thirty (30) days from that date pursuant to Texas Rule of Appellate
Notice of Appeal Pg. 1
Procedure 26.1. Appellant’s Notice of Appeal is timely as it is within the time allowed for
timely filing the notice of appeal. Tex. R. Civ. P. §4.
5. Appellant also requests suspension of enforcement of the judgment rendered by the Final
Order of May 28, 2015, pending appeal.
6. Pursuant to Rule 34.5 of the Texas Rules of Appellate Procedure, Appellant respectfully
requests that an undesignated copy of the Clerk's Record be included in the Appellate Record.
7. Contemporaneously with the filing of this Notice of Appeal, Christopher Spates is
serving notice of the appeal on all parties to the Final Order.
WHEREFORE, PREMISES CONSIDERED, Christopher Spates respectfully prays that
this Notice of Appeal be filed amongst the papers in the above-styled and numbered cause and
then assigned to either the First or Fourteenth Court of Appeals so that it may be heard.
Additionally, Appellant prays for such further relief either at law or equity, to which it may
prove itself justly entitled.
Respectfully submitted,
/s/ Taura D. Spates
Taura D. Spates
Texas Bar No. 24071745
P.O. Box 742393
Houston, TX 77274
(713) 203-3861 Ph
(281) 206-2660 Fx
tauraspates@yahoo.com
ATTORNEY FOR APPELLANT,
CHRISTOPHER SPATES
Notice of Appeal Pg. 2
CERTIFICATE OF SERVICE
This is to certify that the above and foregoing Notice of Appeal has been served by delivery of
a true copy on the 29th day of June 2015 as follows:
Daniel Lemkuil
1314 Texas Ave., Suite 1515
Houston, TX 77002
daniel_lemkuil@flash.net
Angela Lancelin
Assistant Attorney General
Office of the Attorney General
By electronic transmission to angela.lancelin@texasattorneygeneral.gov
John Worley
Office of The Attorney General
Appellate Division
John.worley@texasattorneygeneral.gov
/s/ Taura D. Spates
Taura Spates
Notice of Appeal Pg. 3