Nash Jesus Gonzales and Gonzales & Gonzales, P.C. v. Marissa Ann Maggio

ACCEPTED
03-14-00117-CV
4916050
THIRD COURT OF APPEALS
AUSTIN, TEXAS
4/16/2015 1:03:16 PM
JEFFREY D. KYLE
CLERK

NO. 03-14-00117-CV

NASH JESUS GONZALES and § IN THE COURT OF FILED IN
APPEALS
3rd COURT OF APPEALS
GONZALES & GONZALES, P.C., § AUSTIN, TEXAS
Appellants § 4/16/2015 1:03:16 PM
v. § THIRD JUDICIAL JEFFREY
DISTRICT D. KYLE
Clerk
§
MARISSA ANN GONZALES §
Appellee § AUSTIN, TEXAS

APPELLEE'S UNOPPOSED MOTION TO SEAL APPELLEE'S BRIEF

TO THE HONORABLE COURT:

COMES NOW Appellee Marissa Ann Gonzales, and files her Unopposed

Motion to Seal Appellee's Brief and respectfully shows the Court as follows:

I.
MOTION FOR A COPY OF THE RECORD

By order dated September 15, 2011, the trial court ordered the clerk's record

and reporter's record in this case to be sealed. In order to obtain a copy of the

clerk's record and the reporter's record, Appellee was required to file a motion

with this Court. On February 6, 2015, Appellee filed her Unopposed Motion to

Obtain a Copy of the Record.

By letter dated February 9, 2015, the Court of Appeals ordered that

Appellee's motion was granted in part. As requested, the Clerk was ordered to

provide a copy of the record to Appellee. However, regarding Appellee's request

to "cite to and/or include portions of the clerk's record and reporter's record in

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Appellee's Brief and in the Appendix" the Court granted Appellee's request

subject to Appellee's preservation of the confidentiality contemplated by the

sealing order and Rule 9.2(c)(3) ofthe Texas Rules of Appellate Procedure.

Appellee's Brief cites to, quotes from and contains information and records

in its Appendix that are sensitive and confidential as contemplated by the sealing

order. Therefore, in compliance with the Court's letter dated February 9, 2015 and

in order to preserve the trial court's sealing order dated September 15, 2011,

Appellee respectfully requests that the Court order Appellee's Brief be sealed.

Appellee's Brief is due on Friday, April17, 2015.

II.
CONCLUSION AND PRAYER

For the reasons discussed above, Appellee Marissa Ann Gonzales

respectfully requests that the Court grant her Motion to Seal Appellee's Brief and

order that Appellee's Brief be sealed.

Respectfully submitted,

SAVRICK, SCHUMANN, JOHNSON, MCGARR,
KAMINSKI & SHIRLEY, LLP

ilson Shirley II
e Bar No. 00795647
Jessica Marcoux Hall
State Bar No. 24046348
The Overlook at Gaines Ranch
4330 Gaines Ranch Loop, Suite 150
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 Austin, Texas 78735
512-347-1604
512-347-1676 Facsimile
Email: wilson@ssjmlaw.com
Email: jessica@ssjmlaw.com

ATTORNEYS FOR APPELLEE

CERTIFICATE OF CONFERENCE

I certify that I conferred with Thomas Cowart, counsel for Appellants, by
email on April 16, 2015, and he indicated he does not oppose the relief requested
in this motion.

CERTIFICATE OF SERVICE

I certify that a true and correct copy of this Motion for Substitution of
Counsel has been served on the following via the Efile system on this 16th day of
April, 2015:

Thomas B. Cowart, Via email: tom@tcowart. com
WASOFF & COWART, PLLC
100 North Central Expressway, Suite 901
Richardson, Texas 75080

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