Sabre Energy Corporation, SonCo Holdings, LLC, Van W. Mounts and Edwin Wesley Sano v. Well-Pro Service, L.P. ( 2015 )

ACCEPTED
12-15-00054-CV
TWELFTH COURT OF APPEALS
TYLER, TEXAS
5/11/2015 9:58:44 AM
CATHY LUSK
CLERK
NO. 12-15-00054-CV
FILED IN
12th COURT OF APPEALS
IN THE TYLER, TEXAS
5/11/2015 9:58:44 AM
TWELFTH COURT OF APPEALS CATHY S. LUSK
Clerk
TYLER, TEXAS
_________________________
SABRE ENERGY CORPORATION, SONCO HOLDINGS, LLC,
VAN W. MOUNTS AND EDWIN WESLEY SANO
v.
WELL-PRO SERVICES, L.P.
_________________________
Joint Motion to Abate Appeal
All parties, jointly, move the Court to abate this appeal, while the parties
finalize a settlement.
1. The appeal has been perfected, but the appellate record is not yet
complete.
2. Subsequent to a mediation ordered by this Court, the parties have agreed
to resolve all their differences.
3. The settlement is currently executory, and should be finalized within 60
days. In the meanwhile, the appellants desire to preserve their appellate
rights, but without incurring further appellate expenses in the interim.
4. Upon the settlement’s final execution, the parties intend to ask this
Court for entry of further orders as contemplated in the settlement
agreement.
WHEREFORE, PREMISES CONSIDERED, the parties jointly ask the Court
to abate this appeal for 60 days, or until such time as the parties’ settlement has been
consummated. The parties further request all other relief that this motion may
authorize.
This 11th day of May, 2015.
Respectfully submitted,
RAMEY & FLOCK, P.C.
100 East Ferguson, Suite 500
Tyler, TX 75702
Telephone: (903) 597-3301
Facsimile: (903) 597-2413
/s/ Greg Smith
GREGORY D. SMITH
State Bar No. 18600600
gsmith@rameyflock.com
ANDREW S. STINSON
State Bar No. 24028013
andys@rameyflock.com
PAUL GILLIAM
State Bar No. 07938700
paulg@rameyflock.com
Joint Motion to Abate Appeal Page 2
Attorneys for Appellants
/s/ Kyle Kutch
KYLE KUTCH
Attorney at Law
State Bar No. 11770543
211 East Tyler Street, Suite 600-G
Longview, TX 75601
Telephone: (903) 236-8788
Facsimile: (903) 236-0015
kyle@kutchlaw.com
Attorney for Appellee
Joint Motion to Abate Appeal Page 3