ACCEPTED
03-14-00404-CV
7194568
THIRD COURT OF APPEALS
AUSTIN, TEXAS
10/1/2015 4:29:17 PM
JEFFREY D. KYLE
CLERK
No. 03-14-00404-CV
In the Third Court of Appeals FILED IN
3rd COURT OF APPEALS
Austin, Texas AUSTIN, TEXAS
10/1/2015 4:29:17 PM
JEFFREY D. KYLE
Clerk
KEVIN TOWER AND KARRIE LYNN TOWER
Appellants,
V.
BANK OF AMERICA, N.A.
Appellee.
ON APPEAL FROM THE COUNTY COURT AT LAW, HAYS COUNTY, TEXAS
CAUSE NO. 13-0320-C
APPELLEE’S RESPONSE TO MOTION FOR REHEARING
Jonathan M. Williams
jwilliams@mlg-defaultlaw.com
State Bar No. 00791932
MARINOSCI & BAXTER
MARINOSCI LAW GROUP, P.C.
14643 Dallas Parkway, Suite 750
Dallas, Texas 75245
Phone: (972) 331-2100
Fax: (972) 331-5240
ATTORNEYS FOR APPELLEE
BANK OF AMERICA, N.A.
PAGE 1
RESPONSE TO MOTION FOR REHEARING
Appellee files this brief and initial response to Appellants’ Motion for
Rehearing to bring to the Court’s attention that Appellants have not served any
document filed during the pendency of this appeal upon the Appellee and that all
certifications of service by facsimile are not accurate.
Appellee has previously contacted the Appellants at the beginning of the
appeal, by phone, regarding this matter without any response. The only notice that
Appellee has ever received was from the Court.
CONCLUSION AND PRAYER
Appellee therefore respectfully requests that this Court deny Appellants’
Motion for Rehearing.
Respectfully Submitted,
/s/ Jonathan M. Williams
jwilliams@mlg-efaultlaw.com
State Bar No. 00791932
MARINOSCI & BAXTER
MARINOSCI LAW GROUP, P.C.
14643 Dallas Parkway, Suite 750
Dallas, Texas 75245
Phone: (972) 331-2100
Fax: (972) 331-5240
ATTORNEYS FOR APPELLEE
BANK OF AMERICA, N.A.
PAGE 2
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Response to
Motion for Rehearing was served via the following method to the following
persons on the 1stth day of October 2015.
Kevin Tower Via first class mail and
541 Bayou Bend CMRRR# 9407 1118 9956 3833 9527 82
Buda, Texas 78610
Karrie Lynn Tower Via first class mail and
541 Bayou Bend CMRRR# 9407 1118 99556 3833 9576 40
Buda, Texas 78610
/s/ Jonathan M. Williams
Jonathan M. Williams
PAGE 3