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
7/20/2015 3:31:38 PM
CATHY LUSK
CLERK
NO. 12-15-00054-CV
IN THE FILED IN
12th COURT OF APPEALS
TWELFTH COURT OF APPEALS TYLER, TEXAS
7/20/2015 3:31:38 PM
TYLER, TEXAS CATHY S. LUSK
Clerk
_________________________
SABRE ENERGY CORPORATION, SONCO HOLDINGS, LLC,
VAN W. MOUNTS AND EDWIN WESLEY SANO
v.
WELL-PRO SERVICES, L.P.
_________________________
Joint Motion to Remand for
Purposes of Settlement
As authorized in Rule 42.1 of the Texas Rules of Appellate Procedure, the
parties request that the Court would reverse the judgment of the trial court and
remand the cause for purposes of settlement.
1. The notice of appeal and joint motion to abate appeal are the only
pleadings that have been filed in this appellate procedure.
2. The parties have now settled all claims in issue. The settlement
agreement contemplates further action by the trial court.
3. The parties agree that costs of the appeal will be borne by the party
that incurred them.
WHEREFORE, PREMISES CONSIDERED, the parties jointly pray
that the judgment of the trial court would be reversed and that the cause would
be remanded to the trial court for further proceedings in accordance with the
agreement of the parties.
This 20th day of July, 2015.
Respectfully submitted,
RAMEY & FLOCK, P.C.
100 East Ferguson, Suite 500
Tyler, TX 75702
Telephone: (903) 597-3301
Facsimile: (903) 597-2413
/s/ Paul Gilliam
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
Attorneys for Appellants
Joint Motion to Remand for Purposes of Settlement Page 2