Filed 10/7/2015 2:04:36 PM
Shawntel Golden
District Clerk
Lamar County, Texas
Jennifer Frazier
NO. 82395
HALEY BROWN § FILED COURT
IN THE DISTRICT IN
§ 6th COURT OF APPEALS
TEXARKANA, TEXAS
v. § 10/20/2015 9:55:00 AM
§ OF LAMAR COUNTY, TEXAS
DEBBIE AUTREY
RK HALL CONSTRUCTION, § Clerk
LTD §
RKH CAPITAL, LLC, §
STACY LYON d/b/a LYON §
BARRICADE& §
CONSTRUCTION, and §
TEXAS DEPARTMENT OF §
TRANSPORTATION § 62ND JUDICIAL DISTRICT
NOTICE OF INTERLOCUTORY APPEAL
TO THE CLERK OF THE COURT:
COMES NOW, the Defendant, Texas Department of Transportation
("TxDOT"), and gives this Notice of Interlocutory Appeal from the Order Denying
Defendant Texas Department of Transportation's Motion to Dismiss for Lack of
Jurisdiction and No Evidence Motion for Summary Judgment ("Order") of the
Honorable Will Biard, between the Plaintiff, Haley Brown and TxDOT, in the
above captioned cause, signed on September 23, 2015, and filed with you on that
same date. This Notice of Interlocutory Appeal is being filed pursuant to Tex. Civ.
Prac. & Rem Code §51.014(a)(8). And, pursuant to Tex. R. App. P. 28.1(a), this is
an accelerated appeal. Accordingly, and pursuant to Tex. R. App. P. 26.1, this
appeal is being filed within twenty days of the Court's signing of the above Order.
This appeal is taken to the Sixth Court of Appeals at Texarkana, Texas.
Respectfully submitted,
KEN PAXTON
Attorney General of Texas
CHARLES E. ROY
First Assistant Attorney General
JAMES E. DAVIS
Deputy Attorney General for Civil
Litigation
RANDALL K. IDLL
Assistant Attorney General
Chief, Transportation Division
Is/ Garland Williams
GARLAND WILLIAMS
Assistant Attorney General
State Bar No. 24079580
Transportation Division
P.O. Box 12548
Austin, Texas 78711-2548
(512) 463-2004 T
(512) 472-3855 F
garland. williams@texasattorneygeneral.gov
ATTORNEYS FOR DEFENDANT
THE TEXAS DEPARTMffiNT OF
TRANSPORTATION
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CERTIFICATE OF SERVICE
This is to certify that on the 7th day of October, 2015, a true and correct
copy of the foregoing Notice of Interlocutory Appeal has been sent to the
following:
Dale H. Henley
Mayo Mendolia & Vice, L.L.P .,
5368 State Highway 276
Royse City, Texas 75189-5738
Ed Carlton
Quilling, Selander, Lownds, Winslett &
Moser, P.C.
2001 Bryan St., Suite 1800
Dallas, Texas 75201
Brett Myers
David Goodman & Madole
Two Lincoln Tower
5420 LBJ Freeway, Suite 1200
Dallas, Texas 75240
Is/ Garland Williams
GARLAND WILLIAMS
Assistant Attorney General
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