06/03/2015 15:52 FAX 7139263699 Gooden & Gooden 1410002/0003
CAUSE NO. 2014-42890
FILED IN
IVY JANE SIMON § 1st COURT OF APPEALS
IN THE DISTRICT COURT
Plaintiff, HOUSTON, TEXAS
§
§ 6/15/2015 3:33:45 PM
vs. § CHRISTOPHER A. PRINE
Clerk
§ 55TH JUDICIAL DISTRICT
§
§
CYPRESSWOOD SNF OPERATIONS, LLC §
Defendant. § HARRIS COUNTY, TEXAS
PLAINTIFF'S NOTICE OF APPEAL
TO THE HONORABLE WDGE OF SAID COURT:
Plaintiff, Ivy Jane Simon, desires to appeal from the Order Granting Defendant's Motion
to Dismiss for Plaintiff's Failure to Serve Chapter 74 Expert Reports signed by the Court on
February 9, 2015.
Plaintiff appeals to either the First or the Fourteenth Court of Appeals.
Plaintiff has not previously filed a related appeal or original proceeding in either the First
or Fourteenth Court of Appeals.
Respectfully submitted,
~4P~
ELIJAH GOODEN, III
TBN: 08146400
3303 Louisiana St., Suite 125
Houston, Texas 77006
Telephone#: (713) 926-3681
Telecopier #: (713) 926-3699
Attorney for Plaintiff,
IVY JANE SIMON
EXHIBIT B
06/03/2015 15:52 FAX 7139263699 Gooden & Gooden 14!0003/0003
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing instrument was
served upon all parties of rwrd in accordance with the Texas Rules of Civil Procedure, Rules
21a and 191.5, on this the.'-_ day of June, 2015.
E~
Attorney at Law
Robert Hailey
RUSSELL & WRIGHT
Attorney at Law
15770 Dallas Parkway, Suite 1050
Dallas, Texas 75248
viafax: (972) 267-8401
EXHIBIT 8
06/03/2015 15:51 FAX 7139263699 Gooden & Gooden 1410001/0003
GOODEN & GOODEN
ATTORNEYS & COUNSELORS AT LAW
THE PALM COURT BUILDING
3303 LOUISIANA STREET, SUITE 125
HOUSTON, TEXAS 77006
TELEPHONE: (713) 926-3681
TELECOPIER: (713) 926-3699
egoodenatty@sbcglobal.net
ANGELINA D. A. GOODEN ELIJAH GOODEN, III
FACSIMILE TRANSMISSION COVER SHEET
DATE: June 3, 2015 TIME: Lf:56prYJ NUMBER OF PAGES: 3
(including this page)
Please deliver this transmittal to:
ROBERT HAILEY
Attorney Fax: (972) 267-8401
Address: 15770 Dallas Parkway, Suite 1050, Dallas, TX 75248
FROM: ELIJAH GOODEN, Ill
Attorney
RE: PATIENT: FELIX GARCIA .
Request for billing reduction
COMMENTS:
Please see the attached document.
ORIGINAL WILL FOLLOW ORIGINAL WILL NOT FOLLOW _X_
This information in this fax is confidential and/or privileged. This fax is intended to be
reviewed initially by only the individual named above. If the reader of this page is not
the intended recipient. you are hereby notified that any review, dissemination or
copying of this· fax or the information contained herein is prohibited. If you have
received this fax in error, please immediately notify the sender by telephone and return
this fax to the sender at the above address. If problems in transmission are
encountered, please contact sender at the number listed above. Thank you.
EXHIBIT 8
Ivy Jane Simon v. Cypresswood SNF Operations, LLC
Combined Opinion