in Re Jessica Bachelor ( 2015 )

ACCEPTED
01-15-00287-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
4/1/2015 9:59:15 AM
CHRISTOPHER PRINE
CLERK
NO. 01-15-00287-CV
FILED IN
IN THE 1st COURT OF APPEALS
HOUSTON, TEXAS
4/1/2015 9:59:15 AM
FIRST COURT OF APPEALS CHRISTOPHER A. PRINE
Clerk
HOUSTON, TEXAS
JESSICA BACHELOR
RELATOR
v.
ERIC BACHELOR
REAL PARTY IN INTEREST
RELATOR'S MOTION FOR TEMPORARY RELIEF
Stephen Lekas
TX Bar# 12188400
6001 Clinton Dr.
Houston, TX 77020
Tel#: (713) 671-9494
Fax#: (713) 671-9496
NO. 01-15-00287-CV
IN THE
FIRST COURT OF APPEALS
HOUSTON, TEXAS
In Re Jessica Bachelor
Original Proceeding From the 309th
Judicial District Court of Harris County, Texas
MOTION FOR EMERGENCY RELIEF
TO THE HONORABLE FIRST, COURT OF APPEALS:
Pursuant to Texas Rule of Appellate Procedure 52.10, Jessica Bachelor,
Relator, files this Motion for Emergency Relief to accompany her Petition for Writ
of Mandamus and in support of this motion would show the court as follows:
This Motion for Temporary Relief is brought by Relator, Jessica Bachelor,
who shows in support:
I.
Jessica Bachelor filed her Petition for Writ of Mandamus on 3-27-2015
Nicolette Milton certifies that on 3-28-2015, she notified Real Party in Interest,
Eric Bachelor by registered mail that a Motion for Temporary relief would be filed.
Tex. R. App. P. 52.10(a).
II.
The Court may grant temporary relief pending its determination of an
original proceeding. Tex. R. App. P. 52.10(b). This emergency stay is necessary
to preserve jurisdiction in the Trial Court, and the status quo. Furthermore,
immediate relief is requested in the event that Court grants Relator's Motion. See
In re Reed, 901 S.W.2d 604, 609 (Tex. App. - San Antonio 1995)(orig.
Proceeding).
Prayer
Jessica Bachelor, prays that the Court grant her motion for temporary relief
to maintain the status quo of the parties and to preserve the Court's jurisdiction to
consider the merits of Relator's Petition for Writ of Mandamus.
STEPHEN LEKAS
ATTORNEY FOR RELATOR
6001 Clinton Drive
Houston, Texas 77020
(713) 671-9494
(713) 671-9496 (fax)
TBA#12188400
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the Motion for Temporary
Relief was faxed to the opposing counsel and hand delivered to the trial judge on
4-1-2015.
CERTIFICATE OF CONFERENCE
All parties have been notified as of3-28-2015 and have not responded to
Relator's request for agreement.
Real Party in Interest via CMRR
Matthew Skillern
Attorney at Law
701 N. Post Oak, S-207
Houston, TX 77024
Tel: (713)229-8855
Fax: (713) 481-8800
TB# 24041926
Trial Court Judge via hand delivery
Hon. Charley Prine
246th Judicial District Court
20 1 Caroline
Houston, TX 77002
Tel: t I '3 1 $ 5""' 13 ~