ACCEPTED 12-15-00054-CV TWELFTH COURT OF APPEALS TYLER, TEXAS 7/20/2015 3:31:38 PM CATHY LUSK CLERK NO. 12-15-00054-CV IN THE FILED IN 12th COURT OF APPEALS TWELFTH COURT OF APPEALS TYLER, TEXAS 7/20/2015 3:31:38 PM TYLER, TEXAS CATHY S. LUSK Clerk _________________________ SABRE ENERGY CORPORATION, SONCO HOLDINGS, LLC, VAN W. MOUNTS AND EDWIN WESLEY SANO v. WELL-PRO SERVICES, L.P. _________________________

Joint Motion to Remand for Purposes of Settlement

As authorized in Rule 42.1 of the Texas Rules of Appellate Procedure, the parties request that the Court would reverse the judgment of the trial court and remand the cause for purposes of settlement.

1. The notice of appeal and joint motion to abate appeal are the only pleadings that have been filed in this appellate procedure.

2. The parties have now settled all claims in issue. The settlement agreement contemplates further action by the trial court.

3. The parties agree that costs of the appeal will be borne by the party that incurred them.

WHEREFORE, PREMISES CONSIDERED, the parties jointly pray that the judgment of the trial court would be reversed and that the cause would be remanded to the trial court for further proceedings in accordance with the agreement of the parties.

This 20th day of July, 2015.

Respectfully submitted, RAMEY & FLOCK, P.C.

100 East Ferguson, Suite 500 Tyler, TX 75702 Telephone: (903) 597-3301 Facsimile: (903) 597-2413 /s/ Paul Gilliam GREGORY D. SMITH State Bar No. 18600600 [email protected] ANDREW S. STINSON State Bar No. 24028013 [email protected] PAUL GILLIAM State Bar No. 07938700 [email protected] Attorneys for Appellants

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