International Business MacHines Corp., Appellants/Cross-Appellees v. Lufkin Industries, Inc., Appellee/Cross-Appellant ( 2015 )

ACCEPTED
12-15-00223-CV
Filed TWELFTH
9/10/2015 11:00:21
COURT AM
OF APPEALS
Reba Squyres, District
TYLER,Clerk
TEXAS
Angelina 9/10/2015
County,2:47:22
Texas PM
Pam Estes
By: Robin Crain,
CLERK
Deputy Clerk
No. CV-02073-13-02
LUFKIN INDUSTRIES, INC., § IN THE DISTRICT COURT OF
FILED IN
Plaintiff, § 12th COURT OF APPEALS
§ TYLER, TEXAS
v. § 9/10/2015
ANGELINA 2:47:22
COUNTY, PM
TEXAS
§ PAM ESTES
INTERNATIONAL BUSINESS § Clerk
MACHINES CORP., et al., § 159TH JUDICIAL DISTRICT
Defendant. §
NOTICE OF APPEAL
Pursuant to Texas Rule of Appellate Procedure 25.1, defendant International Business
Machines Corporation (“IBM”) hereby gives notice of its intent to appeal. IBM desires to appeal
the trial court’s Final Judgment signed on September 10, 2015, together with all written orders,
rulings, and rulings by operation of law adverse to IBM, including but not limited to the denial of
IBM’s motions for directed verdict, IBM’s overruled charge objections, IBM’s denied requests
for inclusion in the charges, denials of IBM’s motions to strike expert witnesses, and denials of
IBM’s motions to disregard jury answers and for judgment notwithstanding the verdict. This
appeal is taken from the 159th District Court of Angelina County, Texas, the Honorable Paul
White presiding, and is taken to the Twelfth Court of Appeals in Tyler, Texas and to the Texas
Supreme Court, if necessary.
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Respectfully submitted,
YETTER COLEMAN LLP
By: ____________________________
Reagan W. Simpson
State Bar No. 18404700
Marc Tabolsky
State Bar No. 24037576
909 Fannin, Suite 3600
Houston, Texas 77010
(713) 632-8000
(713) 632-8002 (Fax)
rsimpson@yettercoleman.com
mtabolsky@yettercoleman.com
ATTORNEYS FOR DEFENDANT IBM
CERTIFICATE OF SERVICE
I certify that, on September 10, 2015, this document was served on the following counsel
for plaintiff by electronic means:
Murry B. Cohen
mcohen@akingump.com
Jim Wetwiska
jwetwiska@akingump.com
Holli Pryor-Baze
hpryorbaze@akingump.com
AKIN GUMP STRAUSS HAUER & FELD LLP
1111 Louisiana, 44th Floor
Houston, Texas 77002
Scott C. Skelton
sskelton@skeltonslusher.com
SKELTON SLUSHER BARNHILL WATKINS WELLS
1616 South Chestnut Street
Lufkin, Texas 75901
______________________________________
Reagan W. Simpson
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