ACCEPTED
14-15-00397-cv
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
7/13/2015 1:40:12 PM
CHRISTOPHER PRINE
CLERK
IN THE
FOURTEENTH COURT OF APPEALS FILED IN
14th COURT OF APPEALS
HOUSTON, TEXAS
HOUSTON DIVISION 7/13/2015 1:40:12 PM
CHRISTOPHER A. PRINE
Clerk
HAVEN CHAPEL UNITED METHODIST CHURCH
VS. NO. 14-15-00397-CV
WILLIAM MICHAEL LEEBRON II AND
BRAZORIA COUNTY COMMISSIONER’S COURT
MOTION TO REINSTATE APPEAL
TO THE HONORABLE JUDGES OF SAID COURT:
COMES NOW, HAVEN CHAPEL UNITED METHODIST CHURCH
and files this Motion to Reinstate Appeal and in support thereof would show the
following:
This Court issued an order and judgment after Appellant filed a Motion to
Transfer Documents to this cause from a Mandamus action sought as it pertains to
the cause herein. (See Exhibit A, attached and incorporated by reference, the same
as if fully copied and set forth herein). Appellant is unaware whether the Court of
Appeals had knowledge that this Motion had been filed at the time of the rendition
of its judgment. Appellant’s Motion was filed on July 06, 2015 and the dismissal
was issued on July 07, 2015. (See Exhibit B, attached and incorporated by
reference, the same as if fully copied and set forth herein.)
Appellant did not pursue its appeal because it had filed for Mandamus Relief
in this cause for which it believed it was entitled. Mandamus was just recently
denied in Cause No. 14-15-00500-CV. (See Exhibit C, attached and incorporated
by reference, the same as if fully copied and set forth herein.
Moreover, Appellant notified the court of same by letter dated June 03, 2015
and requested that this cause remain open until final judgment was rendered in this
cause or by virtue of a ruling on the mandamus. (See Exhibit D, attached and
incorporated by reference, the same as if fully copied and set forth herein.
Additionally, since the trial court has disposed of the other party, Marlene
Mouchette, Appellee’s Motion to Dismiss is now moot, as judgment has rendered
as to all parties. (See Exhibit E, attached and incorporated by reference, the same
as if fully copied and set forth herein).
This Motion is sought in the interest of justice and in the interests of judicial
economy, as well as financial economy as same prevents the opening of a brand
new cause since the matter has now become final.
WHEREFORE PREMISES CONSIDERED, Appellant, Haven Chapel
United Methodist Church prays that this Honorable Court reinstate this appeal for
the reasons set forth herein.
Respectfully submitted,
/s/ Veronica L. Davis
Veronica L. Davis
226 N. Mattson
West Columbia, Texas 77486
(979) 345-2953
vld57atal@yahoo.com
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of this Motion shall be sent to all
opposing counsel by efiling on this the 7th/13th day of July, 2015.
/s/ Veronica L. Davis