ACCEPTED
14-15-01039-CV
FOURTEENTH 12/4/2015
COURT5:29:44 PM
OF APPEALS
Chris Daniel - District Clerk Harris County
HOUSTON, TEXAS
Envelope No. 8104072
12/11/2015 2:16:59 PM
By: Joshua Bovell
CHRISTOPHER PRINE
Filed: 12/4/2015 5:29:44 PM CLERK
CAUSE NO. 2015-03230
FILED IN
14th COURT OF APPEALS
A+ AUTO CARE, LLC, THOMAS TICKNER § HOUSTON,
IN THE DISTRICT COURT TEXAS
OF
§ 12/11/2015 2:16:59 PM
Plaintiffs, § CHRISTOPHER A. PRINE
v. § Clerk
§ HARRIS COUNTY, TEXAS
HEARST NEWSPAPERS, LLC, D/B/A, §
HEARST MEDIA SERVICES, HOUSTON §
CHRONICLE, JOSH GOLD, ERIC PRAVDA, §
AND TYLER DELLER, §
§ 269TH JUDICIAL DISTRICT
Defendants. §
NOTICE OF ACCELERATED INTERLOCUTORY APPEAL
Defendants Hearst Newspapers, LLC d/b/a Hearst Media Services, Houston Chronicle
and Josh Gold, (collectively, “Hearst” or the “Hearst Defendants”), file this Notice of
Accelerated Interlocutory Appeal pursuant to Chapter 51.04(a)(12) and Chapter 27.008(b) of the
Texas Civil Practice & Remedies Code, and respectfully show the Court as follows:
1. Defendants Hearst Newspapers, LLC d/b/a Hearst Media Services, Houston
Chronicle and Josh Gold, in A+ Auto Care, LLC, Thomas Tickner v. Hearst Newspapers, LLC,
d/b/a Hearst Media Services, Houston Chronicle, Josh Gold, Eric Pravda, and Tyler Deller,
Cause No. 2015-03230 in the 269th Judicial District Court of Harris County, Texas, desire to
appeal from the Order signed by the Hon. Dan Hinde on November 17, 2015, denying in part the
Hearst Defendants’ motion to dismiss pursuant to the Texas Citizens Protection Act, TEX. CIV.
PRAC. & REM. CODE ch. 27, along with all rulings subsumed or incorporated therein.
2. The Order appealed from was signed on November 17, 2015. A copy of the
Order is attached hereto as Exhibit A. This Notice of Accelerated Interlocutory Appeal is filed
within twenty (20) days of the interlocutory order. See TEX. R. APP. P. 26.1(b).
3. Defendants Hearst Newspapers, LLC d/b/a Hearst Media Services, Houston
Chronicle and Josh Gold desire to appeal that part of the attached Order denying their motion to
dismiss filed under Chapter 27 of the Texas Civil Practice & Remedies Code.
4. The appeal is hereby taken to the First or Fourteenth District Court of Appeals,
Houston, Texas.
5. This notice is filed by Defendants Hearst Newspapers, LLC d/b/a Hearst
Media Services, Houston Chronicle and Josh Gold.
6. The appeal of this case is an accelerated appeal.
7. This case is not a parental termination or child protection case, as defined in Rule
28.4.
8. I certify there is no related appeal or original proceeding that has been previously
filed in either the First or Fourteenth District Court of Appeals.
9. The Hearst Defendants have or will make arrangements to obtain and pay for the
Clerk’s Record in this matter. The Hearst Defendants have or will make arrangements to obtain
and pay for the Reporter’s Record in this matter.
DATED and FILED this 4th day of December, 2015.
Respectfully Submitted,
By: _/s/ Jonathan R. Donnellan_________________
Jonathan R. Donnellan (State Bar No. 24063660)
Office of General Counsel
The Hearst Corporation
300 West 57th Street
New York, NY 10019
Telephone: 212-841-7000
Facsimile: 212-554-7000
jdonnellan@hearst.com
2
Attorney for Defendants Hearst Newspapers, LLC
d/b/a Hearst Media Services, Houston Chronicle
and Josh Gold
3
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was served on all counsel of
record on this the 4th day of December, 2015, by the E-File system.
___/s/_ Jonathan R. Donnellan_______
Jonathan R. Donnellan
4