Filed: 8/11/2015 4:16:59 PM
Sharena Gilliland
District Clerk
Parker County, Texas
Mary Rogers
NO. CV13-0164
FILED IN
TARA GOODE § IN THE DISTRICT 2nd
COURT
COURT OF APPEALS
Plaintiff, § FORT WORTH, TEXAS
§ 8/12/2015 4:51:29 PM
V. § 415TH JUDICIAL DISTRICT
DEBRA SPISAK
§ Clerk
JERRY EMBRY §
Defendant. § OF PARKER COUNTY, TEXAS
NOTICE OF APPEAL
Plaintiff, Tara Goode, party to this case, files this Notice of Appeal seeking to alter the
trial court's judgment or other appealable order.
The trial court, trial court case number and style of this matter are shown in the above
caption.
The judgment or order appealed from was signed on July 14, 2014.
Tara Goode desires to appeal the trial Court's granting of "Jerry Embry's No Evidence
Motion for Summary Judgment" and "Defendant Jerry Embry's Motion for Summary
Judgment.".
This appeal is being taken to the Second Court of Appeals.
This notice is being filed by Tara Goode.
Respectfully submitted,
JARVIS LAW FIRM
By: /s/ Donnie Jarvis
Donnie Jarvis
Texas Bar No. 90002001
Email: don@jarvislawfirm.com
116 South Crockett St.
Sherman, Texas 75090
Tel. (903) 891-8898
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1
Fax. (903) 891-8895
Attorney for Plaintiff
Tara Goode
CERTIFICATE OF SERVICE
I certify that on August 11, 2015 a true and correct copy of Plaintiff's Notice of Appeal
was served by fax on Michael W. Minton at (817) 377-9201.
/s/ Donnie Jarvis
Donnie Jarvis
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2
98
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CAUSE: CV13-o164 2p, 4
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TARA GOODE § IN THE DISTRICI‘ CO / 0
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JERRY EMBRY, §
DEANNA SMITH AND CADE SMITH § ,
On this day came on to be considered the traditional and no evidence motions for
summary judgment filed by defendant Jerry Embry. The Court, having considered the
evidence, is of the opinion that said motions should be, and are hereby GRANTED.
IT IS, THEREFORE, ORDERED ADJ UDGED AND DECREED that Jerry
Embry’s no evidence and traditional motions for summary judgment are granted, and
judgment is hereby entered that plaintiff take nothing by her claims against him,
%
defendant to have and recover his costs of court.
All relief not expressly granted herein is denied. This order disposes of all parties
and all issues, is final and appealable.
Signed this ( 2 day of , 2015.
J UDGE éRESIDING
ORDER ON DEFENDANT JERRY EMBRY’S MOTION FOR SUMMARY JUDGMENT
Pageiofi
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Filed: 8/12/2015 9:50:48 AM
Sharena Gilliland
District Clerk
Parker County, Texas
Jason Nowak
NO. CV13-0164
TARA GOODE § IN THE DISTRICT COURT
Plaintiff, §
§
V. § 415TH JUDICIAL DISTRICT
§
JERRY EMBRY §
Defendant. § OF PARKER COUNTY, TEXAS
PLAINTIFF'S MOTION FOR A NEW TRIAL
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES Plaintiff, Tara Goode, Movant herein, in the interest of justice and
fairness, and brings this Motion for New Trial. In support hereof, Movant shows the following:
I.
A. The Court erred in granting Defendant’s Motions for Summary Judgment titled
“Jerry Embry’s No Evidence Motion for Summary Judgment” and “Defendant Jerry Embry’s
Motion for Summary Judgment.”
II.
A. Movant requests an evidentiary hearing on the allegations raised herein.
WHEREFORE, PREMISES CONSIDERED, Movant prays this Court will vacate the
judgment in this matter and will grant Movant a new trial for the grounds specified herein and in
the interest of fairness and justice, and for such other and further relief that may be awarded at
law or in equity.
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4
Respectfully submitted,
JARVIS LAW FIRM
By: /s/Donnie Jarvis
Donnie Jarvis
Texas Bar No. 90002001
Email: don@jarvislawfirm.com
116 South Crockett St.
Sherman, Texas 75090
Tel. (903) 891-8898
Fax. (903) 891-8895
Attorney for Plaintiff
Tara Goode
CERTIFICATE OF SERVICE
I certify that on August 11, 2015 a true and correct copy of Plaintiff's Motion for New
Trial was served by fax on Michael W. Minton at (817) 377-9201.
/s/ Donnie Jarvis
Donnie Jarvis
ORDER SETTING HEARING
The above and foregoing Plaintiff's Motion for New Trial having been presented and duly
considered, the Court is of the opinion that a hearing on same is necessary.
IT IS THEREFORE ORDERED that said Motion is set for hearing on ___________ at
_______, in the 415TH Judicial District Court of Parker County, Texas.
SIGNED on , 2015.
JUDGE PRESIDING
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Filed: 8/12/2015 9:58:34 AM
Sharena Gilliland
District Clerk
Parker County, Texas
Mary Rogers
NO. CV13-0164
TARA GOODE § IN THE DISTRICT COURT
Plaintiff, §
§
V. § 415TH JUDICIAL DISTRICT
§
JERRY EMBRY §
Defendant. § OF PARKER COUNTY, TEXAS
AMENDED NOTICE OF APPEAL
Plaintiff, Tara Goode, party to this case, files this Notice of Appeal seeking to alter the
trial court's judgment or other appealable order.
The trial court, trial court case number and style of this matter are shown in the above
caption.
The judgment or order appealed from was signed on July 14, 2015.
Tara Goode desires to appeal the trial Court's granting of "Jerry Embry's No Evidence
Motion for Summary Judgment" and "Defendant Jerry Embry's Motion for Summary
Judgment.".
This appeal is being taken to the Second Court of Appeals.
This notice is being filed by Tara Goode.
Respectfully submitted,
JARVIS LAW FIRM
By: /s/ Donnie Jarvis
Donnie Jarvis
Texas Bar No. 90002001
Email: don@jarvislawfirm.com
116 South Crockett St.
Sherman, Texas 75090
Tel. (903) 891-8898
1
6
Fax. (903) 891-8895
Attorney for Plaintiff
Tara Goode
CERTIFICATE OF SERVICE
I certify that on August 12, 2015 a true and correct copy of Plaintiff's Notice of Appeal
was served by fax on Michael W. Minton at (817) 377-9201.
/s/ Donnie Jarvis
Donnie Jarvis
2
7