City of Farmers Branch v. Stacy Wright ( 2015 )

ACCEPTED
FILED
05-15-01497-CV
DALLAS COUNTY
05-15-01497-CV FIFTH121812015
COURT OF APPEALS
12:55:00
DALLAS,
PM
TEXAS
FELICIA PITRE
12/9/2015 10:30:36
DISTRICT CLERKAM
LISA MATZ
CLERK
Bridgette Vation
CAUSE NO. DC-15-02269
STACY WRIGHT, § IN THE DISTRICT COURT
§ RECEIVED IN
Plaintiff, § 5th COURT OF APPEALS
§ DALLAS, TEXAS
v. § 12/9/2015 10:30:36 AM
§ 162ND JUDICIALLISA MATZ
DISTRICT
CITY OF FARMERS BRANCH, TEXAS, § Clerk
§
Defendant. § DALLAS COUNTY, TEXAS
DEFENDANT CITY OF FARMERS BRANCH'S NOTICE OF APPEAL
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Defendant City of Farmers Branch ("Defendant" or "City"), and files this,
its Notice of Appeal. In support thereof, the City respectfully shows the Court as follows:
1. Defendant City of Farmers Branch desires to appeal from the Court's Order on Defendant
City of Farmers Branch's Plea to the Jurisdiction/Motion to Dismiss for Lack of Subject
Matter Jurisdiction, signed by this court on November 18, 2015.
2. Defendant appeals to the Court of Appeals for the Fifth District of Texas at Dallas.
3. The appeal of this case is an accelerated appeal, pursuant to Tex.Civ.P. & Rem.C.
§51.014(a)(8), and pursuant to Tex.Civ.P. & Rem.C. §51.014(b), this appeal stays the
commencement of trial and all other proceedings in the Trial Court pending resolution of
this appeal.
Defendant City of Farmers Branch's Notice of Appeal Page I of2
NoticeAppeal
Respectfully submitted,
WALKER BRIGHT PC
100 N. Central Expressway, Suite 800
Richardso e s 75080
Telepho : 72) 744-0192
Facsi · (97 ) 744-0067
Gera d Bright
State Bar No. 02991720
David L. Craft
State Bar No. 00790522
Attorneys for Defendant
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing Defendant City of Farmers
Branch's Notice of Appeal has been transmitted via facsimile to all counsel ofrecord and/or parties
as listed below on this the gth day of December, 2015.
John P. Hagan Via Facsimile@ (469)208-5366
Hagan Law Group
1333 West McDermott Dr., Suite 200
Allen, Texas 75013
)
Attorney.for Plaintiff
I
Defendant City offarmers Branch's Notice of Appeal Page 2 of2
NoticeAppeal