Donna Kohlhausen, as Independent of the Estate of Valleyssa Joste Cerra v. Brian Keith Baxendale, as Independent of the Estate of Kelley William Joste AKA William Kelley Joste ( 2015 )

ACCEPTED
01-15-00901-CV
DV PROBATE COURT 2 FIRST COURT OF FILED
APPEALS
10/21/2015 10:23:00 AM
HOUSTON, TEXAS
Stan 3:20:58
11/10/2015 Stanart PM
County Clerk
CHRISTOPHER PRINE
Harris County
CLERK
Cause No. 295986-401
DONNA KOHLHAUSEN, as § IN THE PROBATE COURT
FILED IN
Independent Executor of the Estate of § 1st COURT OF APPEALS
Valleyssa Joste Cerra, § HOUSTON, TEXAS
Plaintiff, § 11/10/2015 3:20:58 PM
§ CHRISTOPHER A. PRINE
v. § ClerkNo. 2
§
BRIAN KEITH BAXENDALE, as §
Independent Executor of the Estate of §
Kelley William Joste aka William Kelley §
Joste, §
Defendant. § OF HARRIS COUNTY, TEXAS
§
NOTICE OF APPEAL
Plaintiff Donna Kohlhausen, as Independent Executor of the Estate of Valleyssa Joste
Cerra (“Plaintiff”) appeals from the probate court’s order granting Defendant Brian Keith
Baxendale, as Independent Executor of the Estate of Kelley William Joste’s motion for
summary judgment signed on August 11, 2015, the probate court’s order denying Plaintiff’s
motion for reconsideration signed on October 6, 2015, and all adverse interlocutory rulings
that merged into the judgment. Plaintiff takes this appeal to either the First or Fourteenth Court
of Appeals.
Plaintiff respectfully asks the trial clerk to send a copy of this notice of appeal
immediately to the appellate court clerk and to the court reporter responsible for preparing the
reporter’s record.
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Respectfully submitted,
JOHNS MARRS ELLIS & HODGE LLP
/s/ Joseph R. Marrs
Joseph R. Marrs
State Bar No. 24037029
jmarrs@jmehlaw.com
Leah K. Lanier
State Bar No. 24080068
llanier@jmehlaw.com
500 Dallas Street, Suite 1350
Houston, Texas 77002
(713) 609-9503
(713) 583-5825 fax
Attorneys for Plaintiff Donna Kohlhausen, as
Independent Executor of the Estate of Valleyssa
Joste Cerra, Plaintiff
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CERTIFICATE OF SERVICE
This is to certify that on October 21, 2015, a true and correct copy of the foregoing was
sent to the following:
James H. Stilwell Via E-Service
1400 Woodloch Forest Drive, Ste. 590
The Woodlands, TX 77380
(281) 419-6200
/s/ Joseph R. Marrs
Joseph R. Marrs
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