Donna Kohlhausen, as Independent of the Estate of Valleyssa Joste Cerra v. Brian Keith Baxendale, as Independent of the Estate of Kelley William Joste AKA William Kelley Joste

ACCEPTED 01-15-00901-CV DV PROBATE COURT 2 FIRST COURT OF FILED APPEALS 10/21/2015 10:23:00 AM HOUSTON, TEXAS Stan 3:20:58 11/10/2015 Stanart PM County Clerk CHRISTOPHER PRINE Harris County CLERK Cause No. 295986-401 DONNA KOHLHAUSEN, as § IN THE PROBATE COURT FILED IN Independent Executor of the Estate of § 1st COURT OF APPEALS Valleyssa Joste Cerra, § HOUSTON, TEXAS Plaintiff, § 11/10/2015 3:20:58 PM § CHRISTOPHER A. PRINE v. § ClerkNo. 2 § BRIAN KEITH BAXENDALE, as § Independent Executor of the Estate of § Kelley William Joste aka William Kelley § Joste, § Defendant. § OF HARRIS COUNTY, TEXAS § NOTICE OF APPEAL Plaintiff Donna Kohlhausen, as Independent Executor of the Estate of Valleyssa Joste Cerra (“Plaintiff”) appeals from the probate court’s order granting Defendant Brian Keith Baxendale, as Independent Executor of the Estate of Kelley William Joste’s motion for summary judgment signed on August 11, 2015, the probate court’s order denying Plaintiff’s motion for reconsideration signed on October 6, 2015, and all adverse interlocutory rulings that merged into the judgment. Plaintiff takes this appeal to either the First or Fourteenth Court of Appeals. Plaintiff respectfully asks the trial clerk to send a copy of this notice of appeal immediately to the appellate court clerk and to the court reporter responsible for preparing the reporter’s record. 1 Respectfully submitted, JOHNS MARRS ELLIS & HODGE LLP /s/ Joseph R. Marrs Joseph R. Marrs State Bar No. 24037029 jmarrs@jmehlaw.com Leah K. Lanier State Bar No. 24080068 llanier@jmehlaw.com 500 Dallas Street, Suite 1350 Houston, Texas 77002 (713) 609-9503 (713) 583-5825 fax Attorneys for Plaintiff Donna Kohlhausen, as Independent Executor of the Estate of Valleyssa Joste Cerra, Plaintiff 2 CERTIFICATE OF SERVICE This is to certify that on October 21, 2015, a true and correct copy of the foregoing was sent to the following: James H. Stilwell Via E-Service 1400 Woodloch Forest Drive, Ste. 590 The Woodlands, TX 77380 (281) 419-6200 /s/ Joseph R. Marrs Joseph R. Marrs 3