ACCEPTED
04-15-00147-CV
04-15-00147-CV FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
3/16/2015 7:52:49 PM
KEITH HOTTLE
CLERK
No. 2014-CVQ-000557 D3
JULIAN JACOBO REYNA § IN THE DISTRICT COURT
FILED IN
§ 4th COURT OF APPEALS
V. § SAN ANTONIO, TEXAS
§ 341st JUDICIAL 03/16/2015 7:52:49 PM
DISTRICT
FRANCISCO RODRIGUEZ, THE § KEITH E. HOTTLE
LAREDO POLICE DEPARTMENT, § Clerk
AND THE CITY OF LAREDO, TEXAS § WEBB COUNTY, TEXAS
NOTICE OF APPEAL
TO THE HONORABLE JUDGE OF SAID COURT:
The Defendant, City of Laredo, Texas, gives notice of its desire to appeal the trial
court’s Order on the City of Laredo’s Third Plea to the Jurisdiction signed on March 2, 2014.
This Order is attached to this Notice. This appeal is taken to the Fourth Court of Appeals
for the State of Texas, sitting in San Antonio, Texas. Section 51.014(a)(8) of the Civil
Practices and Remedies Code grants this Court interlocutory jurisdiction over “an
interlocutory order of a district court” that “grants or denies a plea to the jurisdiction by a
governmental unit as that term is defined in Section 101.001." Tex. Civ. Prac. & Rem. Code
Ann. § 51.014(a)(8) (West Supp. 2011). The trial court denied the City of Laredo’s plea to
the jurisdiction in which it challenged the trial court’s subject-matter jurisdiction over the
case in which the appealed-from order was issued.
Respectfully submitted,
LAW OFFICES OF ALBERT LÓPEZ
14310 Northbrook Dr., Suite 200
San Antonio, Texas 78232
Telephone: (210) 404-1983
Fax: (210) 404-1990
By: /s/ Albert López
ALBERT LÓPEZ
State Bar No. 12562350
alopezoffice@gmail.com
ATTORNEYS FOR DEFENDANT
CITY OF LAREDO
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing instrument
was served by electronic service upon to Mr. Andres Reyes, 401 Hillside Rd., Capitol Centre,
Laredo, Texas 78041 on March 16, 2015.
/s/ Albert López
Albert López
City of Laredo, Texas v. Julian Jacobo Reyna
Combined Opinion