Sabre Energy Corporation, SonCo Holdings, LLC, Van W. Mounts and Edwin Wesley Sano v. Well-Pro Service, L.P.

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ACCEPTED 12-15-00054-CV TWELFTH COURT OF APPEALS TYLER, TEXAS 5/11/2015 9:58:44 AM CATHY LUSK CLERK NO. 12-15-00054-CV FILED IN 12th COURT OF APPEALS IN THE TYLER, TEXAS 5/11/2015 9:58:44 AM TWELFTH COURT OF APPEALS CATHY S. LUSK Clerk TYLER, TEXAS _________________________ SABRE ENERGY CORPORATION, SONCO HOLDINGS, LLC, VAN W. MOUNTS AND EDWIN WESLEY SANO v. WELL-PRO SERVICES, L.P. _________________________ Joint Motion to Abate Appeal All parties, jointly, move the Court to abate this appeal, while the parties finalize a settlement. 1. The appeal has been perfected, but the appellate record is not yet complete. 2. Subsequent to a mediation ordered by this Court, the parties have agreed to resolve all their differences. 3. The settlement is currently executory, and should be finalized within 60 days. In the meanwhile, the appellants desire to preserve their appellate rights, but without incurring further appellate expenses in the interim. 4. Upon the settlement’s final execution, the parties intend to ask this Court for entry of further orders as contemplated in the settlement agreement. WHEREFORE, PREMISES CONSIDERED, the parties jointly ask the Court to abate this appeal for 60 days, or until such time as the parties’ settlement has been consummated. The parties further request all other relief that this motion may authorize. This 11th day of May, 2015. Respectfully submitted, RAMEY & FLOCK, P.C. 100 East Ferguson, Suite 500 Tyler, TX 75702 Telephone: (903) 597-3301 Facsimile: (903) 597-2413 /s/ Greg Smith GREGORY D. SMITH State Bar No. 18600600 gsmith@rameyflock.com ANDREW S. STINSON State Bar No. 24028013 andys@rameyflock.com PAUL GILLIAM State Bar No. 07938700 paulg@rameyflock.com Joint Motion to Abate Appeal Page 2 Attorneys for Appellants /s/ Kyle Kutch KYLE KUTCH Attorney at Law State Bar No. 11770543 211 East Tyler Street, Suite 600-G Longview, TX 75601 Telephone: (903) 236-8788 Facsimile: (903) 236-0015 kyle@kutchlaw.com Attorney for Appellee Joint Motion to Abate Appeal Page 3