Peter G. Milne, P.C., Peter G. Milne, Individually, and Healy, Milne & Associates, P.C. v. Val Ryan and Joy Ryan

ACCEPTED 06-14-00106-CV SIXTH COURT OF APPEALS TEXARKANA, TEXAS Appellate Docket Number: 12/23/2014 12:15:16 PM DEBBIE AUTREY Appellate Case Style: CLERK Vs. Companion Case No.: FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 12/29/2014 9:57:00 AM Amended/corrected statement: DOCKETING STATEMENT (Civil) DEBBIE AUTREY Clerk Appellate Court:6th Court of Appeals (to be filed in the court of appeals upon perfection of appeal under TRAP 32) I. Appellant II. Appellant Attorney(s) ❑ Person 6 Organization (choose one) A Lead Attorney Organization Name: Peter G. Milne, P.C. First Name: Chad First Name: Middle Name: Middle Name: Last Name: Parker Last Name: Suffix: Suffix: Law Firm Name: The Parker Firm, P.C. Pro Se: 0 Address 1: 3808 Old Jacksonville Rd. Address 2: City: Tyler State: Texas Zip- 4: 75701 Telephone: 903-595-4541 ext. Fax: 903-595-2864 Email: cparker@theparkerfirm.net SBN: 00786153 I. Appellant 11. Appellant Attorney(s) .0- Person E Organization (choose one) a Lead Attorney First Name: Chad First Name: Peter Middle Name: Middle Name: G. Last Name: Parker Last Name: Milne Suffix: Suffix: Law Firm Name: The Parker Firm, P.C. Pro Se: 0 Address 1: 3808 Old Jacksonville Rd. Address 2: Page 1 of 10 City: State: Texas Zip+4: Telephone: 903-59111111.1111 ext. Fax: 903-595-2864 Email: cparker@theparkerfirm.nell.M11.1.1 SBN: 00786153 1. Appellant 11. Appellant Attorney(s) Person E Organization (choose one) El Lead Attorney Organization Name: Healy, Milne & Associates, P.C. First Name: Peter First Name: Middle Name: G Middle Name: Last Name: Milne Last Name: Suffix: Suffix: Law Firm Name: Pro Se: (j) Address 1: 011111111111111111111111111111111111•In Address 2: City: State: Texas Zip+4: Telephone: 903-5911111.111 ext. Fax: 903-593-9325'' Email: pmilne@tylertaxlaW l SBN: 24037118 111. Appellee IV. Appellee Attorney(s) Person Organization (choose one) E Lead Attorney First Name: James First Name: Middle Name: itoll111•1111 Middle Name: Last Name: Holmes Last Name: Ryan Suffix: Suffix: Law Firm Name: Law Offices of James Holmes, P.411111111111111 Pro Se: Address 1: 212 South Marshall Address 2: City: Henderson State: Texas Zip+4: 75654 Telephone: 903-657-2800 ext. Fax: 903-657-2855 Email: jh@jamesholmeslaw.com SBN: 00784290 HI. Appellee IV. Appellee Attorney(s) Ei Person Organization (choose one) E Lead Attorney First Name: James First Name: Joy Middle Name: Page 2 of 10 Middle Name: Last Name: Holmes Last Name: Ryan Suffix: Suffix: Law Firm Name: Law Offices of James Holmes P.C. Pro Se: 0 Address 1: 12 micwattallillI111111111111111. Address 2: City: 11111.11111=1111111111111111111 State: Texas Zip+4: Telephone: 903-657 22800 ext. Fax: 903-657-2855 Email: jh@jamesholmeslaw.cornM1111111111111111.1 SBN: 00784290 Page 3 of 10 V. Perfection Of Appeal And Jurisdiction Nature of Case (Subject matter or type of case): Professional Malpractice Date order or judgment signed: November 26, 2014 Type of judgment: Interlocutory Order Date notice of appeal filed in trial court: December 17, 2014 If mailed to the trial court clerk, also give the date mailed: Interlocutory appeal of appealable order: Yes ❑ No If yes, please specify statutory or other basis on which interlocutory order is appealable (See TRAP 28): Texas, Ciyil Practices,& Remedies Code 51.014(a)(3) Accelerated appeal (See TRAP 28): Ni Yes ❑ No If yes, please specify statutory or other basis on which appeal is accelerated: Appealable interlocutory order Parental Termination or Child Protection? (See TRAP 28.4): ❑ Yes 0 No Permissive? (See TRAP 28.3): ❑ Yes ❑ No If yes, please specify statutory or other basis for such status: ri Agreed? (See TRAP 28.2): ❑ Yes Z No If yes, please specify statutory or other basis for such status: Appeal should receive precedence, preference, or priority under statute or rule: ❑ Yes Z No If yes, please specify statutory or other basis for such status: Does this case involve an amount under $100,000? ❑ Yes [S]No Judgment or order disposes of all parties and issues: ❑ Yes [Z]No Appeal from final judgment: ❑ Yes Z No Does the appeal involve the constitutionality or the validity of a statute, rule, or ordinance? ❑ Yes No VI. Actions Extending Time To Perfect Appeal Motion for New Trial: E] Yes ❑ No If yes, date filed: Motion to Modify Judgment: ❑ Yes ❑ No If yes, date filed: Request for Findings of Fact ❑ Yes [1] No If yes, date filed: 1111111111111111 and Conclusions of Law: ❑ Yes [I] No If yes, date filed: Motion to Reinstate: ❑ Yes ❑ No If yes, date filed: Motion under TRCP 306a: Other: [:1 Yes [I] No If other, please specify: VII. Indigency Of Party: (Attach file-stamped copy of affidavit, and extension motion if filed.) Affidavit filed in trial court: ❑ Yes ❑ No If yes, date filed: Contest filed in trial court: ❑ Yes Z No If yes, date filed: Date ruling on contest due: Ruling on contest: ❑ Sustained ❑ Overruled Date of ruling: Page 4 of 10 VIII. Bankruptcy Has any party to the court's judgment filed for protection in bankruptcy which might affect this appeal? ❑ Yes No If yes, please attach a copy of the petition. Date bankruptcy filed: Bankruptcy Case Number: IX. Trial Court And Record Court: Fourth Judicial District Court Clerk's Record: County: Rusk Trial Court Clerk: 0 District ❑ County Trial Court Docket Number (Cause No.): Was clerk's record requested? ❑ Yes 0 No If yes, date requested: Trial Judge (who tried or disposed of case): If no, date it will be requested: First Name: Were payment arrangements made with clerk? Middle Name: ❑ Yes ❑No ❑ Indigent Last Name: Gossett (Note: No request required under TRAP 34.5(a),(b)) Suffix: Address 1: 115 N. Main St., Suite 303 Address 2 : City: Henderson State: Texas Zip + 4: 75652 Telephone: 903-657-0358 ext. Fax: 903-655-1250 Email: Reporter's or Recorder's Record: Is there a reporter's record? Ezi Yes ❑ No Was reporter's record requested? ❑ Yes No Was there a reporter's record electronically recorded? 0 Yes ❑ No If yes, date requested: If no, date it will be requested: December 31, 2014 Were payment arrangements made with the court reporter/court recorder? 0 Yes ❑ No ❑ Indigent Page 5 of 10 Court Reporter ❑ Court Recorder ❑ Official ❑ Substitute First Name: Middle Name: Last Name: 111111111111111161 ''''' — ''',: Suffix: Address 1: Address 2: 2: IIIIIIIIIIIIIIIMIIIIIIWINIIIIIIIIII . City: rie/46' ; 61riMii i State: Texas Zip + 4: 75611111111.1 Telephone: 903-657-0358 ext. Fax: 903-655-1250 Email: tboling@co.rusk.tx.us X. Supersedeas Bond Supersedeas bond filed: ❑ Yes ► No If yes, date filed: Will file: ❑ Yes 0 No Xl. Extraordinary Relief , Will you request extraordinary relief (e.g. temporary or ancillary reIieI) from this Court? ❑ Yes a No If yes, briefly state the basis for your request: XII. Alternative Dispute Resolution/Mediation (Complete section if filing in the 1st, 2nd, 4th, 5th, 6th, 8th, 9th, 10th, 11th, 12th, 13th, or 14th Court of Appeal) Should this appeal be referred to mediation? a Yes No If no, please specify: Has the case been through an ADR procedure? ❑Yes a No If yes, who was the mediator? What type of ADR procedure? At what stage did the case go through ADR? ❑ Pre Trial - ❑ Post Trial - ❑ Other If other, please specify: Type of case? Professional Malpractice Give a brief description of the issue to be raised on appeal, the relief sought, and the applicable standard for review, if known (without prejudice to the right to raise additional issues or request additional relief): Court abused its discretion in entering interlocutory order that granted in part appellees motion for class certification against appellant where requisites for class certification not met. How was the case disposed of? Other Summary of relief granted, including amount of money judgment, and if any, damages awarded. Interlocutory order granting in part class certification motion If money judgment, what was the amount? Actual damages: Punitive (or similar) damages: Page 6 of 10 Attorney's fees (trial): Attorney's fees (appellate): Other: If other, please specify: Will you challenge this Court's jurisdiction? ❑ Yes 0 No Does judgment have language that one or more parties "take nothing"? ❑ Yes No Does judgment have a Mother Hubbard clause? ❑ Yes EK No Other basis for finality? Rate the complexity of the case (use I for least and 5 for most complex): ❑ 1 ❑ 2 ❑ 3 El 4 ❑5 ❑ Yes NoPleasmkynwrtohepcdigqusnkowtherpaisnc. Can the parties agree on an appellate mediator? 0 Yes ❑ No If yes, please give name, address, telephone, fax and email address: Name Address Telephone Fax Email . 6111111111111111 Languages other than English in which the mediator should be proficient: Name of person filing out mediation section of docketing statement: Forrest Mays XIII. Related Matters List any pending or past related appeals before this or any other Texas appellate court by court, docket number, and style. Docket Number: Trial Court: Style: Vs. Page 7 of 10 tiling -SIG; Oi714ititotiri;'Orkiii;"e-it§)- , The Courts of Appeals listed above, in conjunction with the State Bar of Texas Appellate Section Pro Bono Committee and local Bar Associations, are conducting a program to place a limited number of civil appeals with appellate counsel who will represent the appellant in the appeal before this Court. The Pro Bono Committee is solely responsible for screening and selecting the civil cases for inclusion in the Program based upon a number of discretionary criteria, including the financial means of the appellant or appellee. If a case is selected by the Committee, and can be matched with appellate counsel, that counsel will take over representation of the appellant or appellee without charging legal fees. More information regarding this program can be found in the Pro Bono Program Pamphlet available in paper form at the Clerk's Office or on the Internet at www.tex-app.org. If your case is selected and matched with a volunteer lawyer, you will receive a letter from the Pro Bono Committee within thirty (30) to forty-five (45) days after submitting this Docketing Statement. Note: there is no guarantee that if you submit your case for possible inclusion in the Pro Bono Program, the Pro Bono Committee will select your case and that pro bono counsel can be found to represent you. Accordingly, you should not forego seeking other counsel to represent you in this proceeding. By signing your name below, you are authorizing the Pro Bono committee to transmit publicly available facts and information about your case, including parties and background, through selected Internet sites and Listsery to its pool of volunteer appellate attorneys. Do you want this case to be considered for inclusion in the Pro Bono Program? ❑ Yes No Do you authorize the Pro Bono Committee to contact your trial counsel of record in this matter to answer questions the committee may have regarding the appeal? ❑ Yes ► 4 No Please note that any such conversations would be maintained as confidential by the Pro Bono Committee and the information used solely for the purposes of considering the case for inclusion in the Pro Bono Program. If you have not previously filed an affidavit of Indigency and attached a file-stamped copy of that affidavit, does your income exceed 200% of the U.S. Department of Health and Human Services Federal Poverty Guidelines? ❑ Yes No These guidelines can be found in the Pro Bono Program Pamphlet as well as on the internet at http://aspe.hhs.gov/poverty/06poverty.shtml. Are you willing to disclose your financial circumstances to the Pro Bono Committee? ❑ Yes cx:j No If yes, please attach an Affidavit of Indigency completed and executed by the appellant or appellee. Sample forms may be found in the Clerk's Office or on the internet at http://www.tex-app.org . Your participation in the Pro Bono Program may be conditioned upon your execution of an affidavit under oath as to your financial circumstances. Give a brief description of the issues to be raised on appeal, the relief sought, and the applicable standard of review, if known (without prejudice to the right to raise additional issues or request additional relief; use a separate attachment, if necessary). XV. Signature Signature of counsel (or pro se party) Date: Printed Name: State Bar No.: Electronic Signature: (Optional) Page 8 of 10 XVI. Certificate of Service The undersigned counsel certifies that this docketing statement has been served on the following lead counsel for all parties to the trial court's order or judgment as follows on December 23, 2014 • Signature of counsel (or pro se party) Electronic Signature: Chad Par. (Optional) Person Served State Bar No.: 00786153 1111 Certificate of Service Requirements (TRAP 9.5(e)): A certificate of service must be signed by the person who made the service and must state: (1) the date and manner of service; (2) the name and address of each person served, and (3) if the person served is a party's attorney, the name of the party represented by that attorney Please enter the following for each person served: Date Served: December 23, 2014 Manner Served: Email First Name: James Middle Name: Last Name: Holmes Suffix: Law Firm Name: Law Offices of James Holmes, P.C. Address 1: 212 South Marshall Address 2: City: Henderson State Texas Zip+4: 75652 Telephone: 903-657-2890„ ext. Fax: ..! 903-657-2855 liPPPII Email: jhgamesholmeslaw.com If Attorney, Representing Party's Name: Val & Joy Ryan Please enter the following for each person served: Page 9 of 10 Date Served: December 23, 2014 Manner Served: Email First Name: Peter Middle Name: G Last Name: Milne Suffix: Law Firm Name: Peter G. Milne, P.C. Address 1: 327 W. Houston Address 2: City: Tyler State Texas Zip+4: 75702 Telephone: 903-593-9300 ext. Fax: 903-593-9325 Email: pmilne@tylertaxlaw.com If Attorney, Representing Party's Name: Healy, Milne & Associates, P.C. Page 10 of 10