Kathleen Barraco v. Levy Townhouse Owners Association, Inc.

FILED
8/4/2015 2:15:18 PM
Donna Kay McKinney
Bexar County District Clerk
Accepted By: Consuelo Gomez

CAUSE NO. 2014 – CI 19385
FILED IN
4th COURT OF APPEALS
SAN ANTONIO, TEXAS
LEVY TOWNHOUSE OWNERS, INC )( IN THE DISTRICT COURT
)( 09/4/2015 2:36:24 PM
)( KEITH
408TH JUDICIAL E. HOTTLE
DISTRICT
Clerk
VS )(
)( BEXAR COUNTY, TEXAS
KATHLEEN BARRACO )(

NOTICE OF APPEAL

This Notice of Appeal is filed by Kathleen Barraco, Respondent, a party to this

proceeding who seeks to alter the trial court's judgment or other appealable order.

1. The trial court, cause number, and style of this case are as shown in the

caption above.

2. Kathleen Barraco desires to appeal from the default judgment granted and

entered on May 1, 2015. Defendant appeals the granting of said judgment as service was

defective in the cause, whereby the court lacked jurisdiction.

3. Defendants Motion for New Trial was filed on June 1, 2015, and denied

by operation of law on July 15, 2015.

4. This appeal is being taken to the Fourth Court of Appeals, San Antonio,

Bexar County Texas..

5. The deadline for filing the Notice of Appeal is August 15, 2015.

Respectfully submitted

_/sBernard Buecker Bar no 03314500
 310 S St Mary’s, # 1220
San Antonio, Texas 78205
Tel. 210 226 1788 Fax. 858 9307
Attorney for Anna Maria Cancino
mastholte@aol.com

CERTIFICATE OF SERVICE

I certify that a true copy of this Notice of Appeal was served in accordance with

rule 9.5 of the Texas Rules of Appellate Procedure on each party or that party's lead

counsel as follows:

Party: LEVY TOWNHOUSE OWNERS, INC

Lead attorney: M. Susan Rice

Address of service: 39340 IH 10 West, Suite D, Boerne, Texas 78006

Method of service: srice@msricelaw.com & fax no. 1 888 840 1597

Date of service: August 3, 2015.

A copy of this notice is being filed with the appellate clerk in accordance with

rule 25.1(e) of the Texas Rules of Appellate Procedure.

_/s Bernard Buecker 3 August 2015
Bernard "Ben" Buecker
Attorney for Respondent, Kathleen Barraco

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