City of Laredo, Texas v. Julian Jacobo Reyna

ACCEPTED 04-15-00147-CV 04-15-00147-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 3/16/2015 7:52:49 PM KEITH HOTTLE CLERK No. 2014-CVQ-000557 D3 JULIAN JACOBO REYNA § IN THE DISTRICT COURT FILED IN § 4th COURT OF APPEALS V. § SAN ANTONIO, TEXAS § 341st JUDICIAL 03/16/2015 7:52:49 PM DISTRICT FRANCISCO RODRIGUEZ, THE § KEITH E. HOTTLE LAREDO POLICE DEPARTMENT, § Clerk AND THE CITY OF LAREDO, TEXAS § WEBB COUNTY, TEXAS NOTICE OF APPEAL TO THE HONORABLE JUDGE OF SAID COURT: The Defendant, City of Laredo, Texas, gives notice of its desire to appeal the trial court’s Order on the City of Laredo’s Third Plea to the Jurisdiction signed on March 2, 2014. This Order is attached to this Notice. This appeal is taken to the Fourth Court of Appeals for the State of Texas, sitting in San Antonio, Texas. Section 51.014(a)(8) of the Civil Practices and Remedies Code grants this Court interlocutory jurisdiction over “an interlocutory order of a district court” that “grants or denies a plea to the jurisdiction by a governmental unit as that term is defined in Section 101.001." Tex. Civ. Prac. & Rem. Code Ann. § 51.014(a)(8) (West Supp. 2011). The trial court denied the City of Laredo’s plea to the jurisdiction in which it challenged the trial court’s subject-matter jurisdiction over the case in which the appealed-from order was issued. Respectfully submitted, LAW OFFICES OF ALBERT LÓPEZ 14310 Northbrook Dr., Suite 200 San Antonio, Texas 78232 Telephone: (210) 404-1983 Fax: (210) 404-1990 By: /s/ Albert López ALBERT LÓPEZ State Bar No. 12562350 alopezoffice@gmail.com ATTORNEYS FOR DEFENDANT CITY OF LAREDO CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing instrument was served by electronic service upon to Mr. Andres Reyes, 401 Hillside Rd., Capitol Centre, Laredo, Texas 78041 on March 16, 2015. /s/ Albert López Albert López