NO. 14-14-00555
IN THE FOURTEENTH COURT OF APPEALS FILED IN
14th COURT OF APPEALS
HOUSTON TEXAS HOUSTON, TEXAS
4/16/2015 7:16:24 AM
CHRISTOPHER A. PRINE
Clerk
LEON LAVIOLETTE and PAMELA LAVIOLETTE,
Appellants,
V.
MICHAEL RUTHERFORD,
Appellee.
Appealed from the 190th District Court,
Harris County, Texas
APPELLANTS' MOTION TO SEAL MEDICAL RECORDS
Jason M. Bone
Texas Bar No. 24001108
P.O. Box 2853
Conroe, TX 77305
Telephone: 936-499-6332
Email: bonejason1@gmail.com
ATTORNEY FOR APPELLANTS,
LEON LAVIOLETTE
APPELLANT REQUESTS ORAL ARGUMENT
NO. 14-14-00555
LEON LAVIOLETTE and PAMELA LAVIOLETTE,
Appellants,
V.
MICHAEL RUTHERFORD,
Appellee.
IDENTITY OF PARTIES & COUNSEL
Leon Laviolette,
Appellant
Represented by:
Jason M. Bone
Texas Bar No. 24001108
P.O. Box 2853
Conroe, TX 77305
Telephone: 936-499-6332
Email: bonejason1@gmail.com
Michael Rutherford,
Appellee
Represented by:
John W. Palisin
Texas Bar No. 15423700
1225 North Loop West, Suite 100
Houston, Texas 77008
Telephone: 713-354-4510
Facsimile: 866-842-6388
Appellants' Motion to Seal Page 2 of 7
Email: jpalisi1@progressive.com
Appellants' Motion to Seal Page 3 of 7
TABLE OF CONTENTS
IDENTITY OF PARTIES & COUNSEL 2-3
STATEMENT OF THE CASE 5
REQUEST FOR ORAL ARGUMENT 5
REQUEST TO SEAL MEDICAL RECORDS 6
PRAYER 6
CERTIFICATE OF COMPLIANCE 7
CERTIFICATE OF SERVICE 7
Appellants' Motion to Seal Page 4 of 7
STATEMENT OF THE CASE
Nature of the case. Appellants sued appellee for monetary damages
for personal injuries from an automobile collision with Appellee.
Course of Proceedings. The trial court dismissed the case for want of
prosecution. Appellants filed a notice of appeal. Appellants did not timely
file their brief. The appeals court ordered appellant to file his brief along
with a motion reasonably explaining why the brief was late on or before
February 12, 2015. Appellants did not file the brief or the motion by such
date and the appeals court dismissed the case for want of prosecution.
Appellants have filed another motion to reinstate which is pending before
the appeals court.
Trial court disposition. The trial court dismissed the case for want of
prosecution.
STATEMENT ON ORAL ARGUMENT
The Court should grant oral argument because oral argument would
give the Court a more complete understanding of the facts presented in this
motion to seal.
Appellants' Motion to Seal Page 5 of 7
REQUEST TO SEAL MEDICAL RECORDS
Appellants, Leon and Pamela Laviolette, request that their attorney,
Jason Bone, be allowed to file his personal and private medical records in
this court in a sealed manner or in a manner that they cannot be view by the
general public on in the Internet or otherwise. The content of the medical
records detail medical conditions and treatment for same and offer a
reasonable explanation, which the appeal's court has requested, as to why
the Appellants' brief was not timely filed.
PRAYER
For the reasons stated in this motion, Appellants ask the Court to
grant this motion and order that Jason Bone may file his private medical
records electronically and that such records will be sealed and not available
to the general public on the Internet or otherwise.
Respectfully submitted,
ason M. Bone
State Bar No.: 24001108
P.O. Box 2853
Conroe, TX 77305
Telephone: 936-499-6332
Email: bonejason1@gmail.com
Attorney for Appellants,
Lee and Pamela Laviolette
Appellants' Motion to Seal Page 6 of 7
CERTIFICATE OF COMPLIANCE
I certify that this document is in a type-face no smaller than 14-point
and the word count of the document is 534.
CERTIFICATE OF SERVICE
I certify that a true and correct copy of this motion was served on
Michael Rutherford through his counsel of record, John W. Palisin byemail
atjpalisi1@progressive.com on April 16, 2015.
son M. Bone
Appellants' Motion to Seal Page 7 of 7