John R. Soard v. Terry Thorn, Shelia Smith and Mary Page

ACCEPTED 12-14-00211-CV TWELFTH COURT OF APPEALS TYLER, TEXAS 6/4/2015 10:27:54 AM CATHY LUSK CLERK No. 12-14-00211-CV JOHN R. SOARD, § IN THE COURT OF FILED APPEALSIN § 12th COURT OF TYLER, TEXAS APPEALS Appellant, § 6/4/2015 10:27:54 AM § CATHY S. LUSK v. § TWELFTH DISTRICT ClerkOF § TEXAS TERRY THORN, SHEILA SMITH, § AND MARY PAGE § § Appellees. § SITTING IN TYLER, TEXAS APPELLEE’S MOTION TO DISMISS APPELLANT’S APPEAL TO THE HONORABLE TYLER COURT OF APPEALS: Appellee Terry Thorn (“Appellee”) files this Motion to Dismiss Appellant’s Appeal as follows: SUMMARY OF ARGUMENT After numerous extensions and without adequate explanation, Appellant John R. Soard (“Soard” or “Appellant”) has failed to file his brief, which was due April 6, 2015. Soard has also failed to comply with the Clerk’s April 9, 2015 notice requiring him to file a motion for extension of time containing a reasonable explanation for his failure to timely file his Appellant’s Brief no later than April 20, 2015. Accordingly, Appellee requests dismissal of his appeal in its entirety for want of prosecution under Tex. R. App. P. 42.3(b) and for Appellant’s failure to comply with the Clerk’s notice under Tex. R. App. P. 42.3(c). 1 BACKGROUND Soard filed his notice of appeal on April 4, 2014. Since that time, he has filed numerous letters complaining of issues related to the completeness of the Clerk’s Record and Reporter’s Record and received numerous extensions of time to file his brief. On March 6, 2015, the Court sent notice to the parties that the case was to be submitted on the Clerk’s Record alone. It ordered Soard to file his Appellant’s Brief on or before April 6, 2015. After Soard failed to file his brief, the Clerk sent its third Notice of Late Brief on April 9, 2015. The Clerk notified Soard that his “appeal may be dismissed for want of prosecution under Tex. R. App. P. 38.8(a)(1) unless a motion for extension of time, containing a reasonable explanation for such failure and showing that Appellee has not suffered material injury thereby, is filed no later than April 20, 2015.” Soard has since filed several more letters, raising the same general complaints he has previously raised regarding the completeness of the record, but he has not moved for an extension of time or explained his failure to file his brief. Thus, he has not complied with the Clerk’s notice. 2 ARGUMENT Under Rule 42.3(b), a court of appeals, on the appellee’s motion or on its own, may dismiss an appeal for want of prosecution when the appellant fails to timely file its brief. Tex. R. App. P. 42.3(b). A court of appeals may also dismiss an appeal when an appellant does not comply with a notice from the clerk requiring a response within a specified time. Tex. R. App. P. 42.3(c). Soard has repeatedly failed to file his Appellant’s Brief, and despite this Court’s granting several extensions of time, ordering that the case be submitted on the Clerk’s Record alone, and imposing an April 6, 2015 deadline for Soard to file his Appellant’s Brief, he still has not done so. Nor has he filed a response to the Clerk’s April 9, 2015 notice. Soard has been cautioned by the Court and has failed to comply. Because pro se litigants must be held to the same standards as any other litigant and must comply with applicable and mandatory rules of pleading and procedure, Soard’s failure to comply with the briefing deadline and Clerk’s notice warrants dismissal of this appeal. Tex. R. App. P. 42.3(b) & (c); see also Morris v. Am. Home Mortg. Servicing, Inc., 360 S.W.3d 32, 36 (Tex. App.—Houston [1st Dist.] 2011, no pet.) (“To apply a different set of rules to pro se litigants 3 would be to give them an unfair advantage over litigants represented by counsel.”). PRAYER Appellee Terry Thorn respectfully requests that the Court: 1.) Dismiss Appellant’s appeal in its entirety; and 2.) Award such other relief to which Appellee is entitled. Respectfully submitted, By: /s/ Michael A. Yanof Michael A. Yanof State Bar No. 24003215 Cassie J. Dallas State Bar No. 24074105 Thompson, Coe, Cousins & Irons, L.L.P. 700 North Pearl St., 25th Floor Dallas, Texas 75201 Telephone: (214) 871-8200 Facsimile: (214) 871-8209 Email: myanof@thompsoncoe.com ATTORNEYS FOR APPELLEE TERRY THORN 4 CERTIFICATE OF COMPLIANCE I certify that this Motion to Dismiss Appellant’s Appeal complies with Tex. R. App. P. 9.4. As to its length, it contains 575 words (not including the matters excluded by Tex. R. App. P. 9.4(i)(1)). Notwithstanding, Rule 9.4(i) does not govern motions. /s/ Michael A. Yanof___________ Michael A. Yanof CERTIFICATE OF SERVICE I hereby certify that on June 4, 2015, a true and correct copy of the foregoing document was served via certified mail, return receipt requested, to: John R. Soard Sheila Smith 38 Delsie St. The Law Office of Sheila Smith Clarksville, AR 72830 P.O. Box 10 Frankston, TX 75763 Mary Page 2201 North Jackson Street Palestine, TX 75801 /s/ Michael A. Yanof___________ Michael A. Yanof 5