City of Krum, Texas v. Taylor Rice ( 2015 )

ACCEPTED
FILED: 10/30/2015 5:03:25 PM02-15-00342-CV
SECOND COURT OF APPEALS
SHERRI ADELSTEIN
Denton County DistrictFORT
ClerkWORTH, TEXAS
11/16/2015 12:25:53 PM
By: Elizabeth Jones, Deputy
DEBRA SPISAK
CLERK
CAUSE NO. 15-02186-367
TAYLOR RICE § IN THE DISTRICT COURT
FILED IN
§ 2nd COURT OF APPEALS
Plaintiff, § FORT WORTH, TEXAS
v. § OF DENTON COUNTY,
11/16/2015 TEXAS
12:25:53 PM
§ DEBRA SPISAK
THE CITY OF KRUM, TEXAS, § Clerk
§
Defendant. § 367th JUDICIAL DISTRICT
NOTICE OF ACCELERATED APPEAL AND AUTOMATIC STAY OF TRIAL COURT
PROCEEDINGS
To the Honorable Judge of this Court:
Under Rule 28 of the Texas Rules of Appellate Procedure, appellant City of Krum, the
defendant in the above action, files this notice of accelerated appeal to the Second
Court of Appeals, Fort Worth, Texas.
Appellant desires to appeal from an interlocutory order entered in the above-styled and
numbered case by this court on October 14, 2015. Specifically, appellant is a
governmental unit appealing the court’s denial of the relief requested within Defendant’s
Plea to the Jurisdiction, Plea in Abatement, and Supporting Brief (filed August 17,
2015).
Under Texas Civil Practice & Remedies Code § 51.014(b), this interlocutory appeal of a
denial of a plea to the jurisdiction made by a governmental entity stays all proceedings
in the trial court, including but not limited to trial proceedings, pending resolution of the
appeal.
This appeal is accelerated under Texas Rule of Appellate Procedure 28.1(a)-(b) and
Texas Civil Practice & Remedies Code § 51.014(a)(8).
Date: October 30, 2015.
Respectfully submitted,
By: /s/David Overcash
Clark McCoy
State Bar No. 90001803
cmccoy@wtmlaw.net
David Overcash
State Bar No. 24075516
david.overcash@wtmlaw.net
2591 Dallas Parkway, Suite 205
NOTICE OF ACCELERATED APPEAL AND AUTOMATIC STAY OF TRIAL COURT PROCEEDINGS
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Frisco, Texas 75034
972.712.3530 telephone
972.712.3540 facsimile
Lance Vanzant
Texas Bar No. 24009746
lvanzant@hbwvlaw.com
Jeffrey A. Hines
Texas Bar No. 09693000
jhines@hbwvlaw.com
512 W. Hickory, Suite 100
P.O. Box 50149
Denton, Texas 76206
940-387-3518 – Tel.
866-546-9247 – Fax
ATTORNEYS FOR CITY OF KRUM, TEXAS
SERVICE CERTIFICATE
A true and correct copy of this document was electronically served on
October 30, 2015, at approximately the same date and time as this
document was electronically filed, via the methods listed below:
VIA ELECTRONIC FILING AND
U.S. CERTIFIED MAIL RRR
#7012 2920 0000 4194 4526
Richard Gladden
1200 W. University Dr, Suite 100
Denton, Texas 76201
Phone: (940) 323-9300
Facsimile: (940) 539-0093
___________________________
David Overcash
NOTICE OF ACCELERATED APPEAL AND AUTOMATIC STAY OF TRIAL COURT PROCEEDINGS
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