Champion Printing & Copying LLC D/B/A Jerry Hayes Photography and Jerry Hayes// Jennifer Nichols Nichols Photographers, Inc. And Jennifer Lindberg D/B/A Jennifer Lindberg Weddings v. Jennifer Nichols Nichols Photographers, Inc. And Jennifer Lindberg D/B/A Jennifer Lindberg Weddings// Champion Printing & Copying LLC D/B/A Jerry Hayes Photography and Jerry Hayes
Champion Printing & Copying LLC D/B/A Jerry Hayes Photography and Jerry Hayes// Jennifer Nichols Nichols Photographers, Inc. And Jennifer Lindberg D/B/A Jennifer Lindberg Weddings v. Jennifer Nichols Nichols Photographers, Inc. And Jennifer Lindberg D/B/A Jennifer Lindberg Weddings// Champion Printing & Copying LLC D/B/A Jerry Hayes Photography and Jerry Hayes
Opinion
ACCEPTED 03-15-00704-CV 8375562 THIRD COURT OF APPEALS LAW OFFICE OF CRAIG BARKER, P.C. AUSTIN, TEXAS 12/28/2015 12:18:10 PM Congress Avenue, Suite 1540, Austin, Texas 78701 JEFFREY D. KYLE Tel: (512) 494-0777; Fax: (512) 553-3197; [email protected] CLERK www.craigbarkerlaw.com December 28, 2015 RECEIVED IN 3rd COURT OF APPEALS VIA ECF AUSTIN, TEXAS 12/28/2015 12:18:10 PM Ms. Patricia Winkler JEFFREY D. KYLE Appeals Clerk II Clerk Travis County District Clerk’s Office Civil Division Re: Cause No. D-1-GN-14-001701, Champion Printing & Copying, LLC d/b/a Jerry Hayes Photography v. Jennifer Nichols, Nichols Photographers, Inc., and Jennifer Lindberg d/b/a/ Jennifer Lindberg Weddings v. Jerry Hayes Photography, in the 345th Judicial District Court of Travis County, Texas Third Court of Appeals case number: 03-15-0070-CV Dear Ms. Winkler: As you know, I am counsel for Cross-Appellants, Jennifer Nichols, Nichols Photographers, Inc., and Jennifer Lindberg d/b/a/ Jennifer Lindberg Weddings, in the above referenced and styled cause and appeal.
In addition to the items requested in our letter filed on December 17, 2015, Cross- Appellants request that two more items be added to the Clerk’s supplemental record and transmitted to the Third Court of Appeals: Judgment Creditors’ motion to contest the net worth statements and bonds posted by the Judgment Debtors, filed on November 10, 2015, and Judge Livingston’s order denying the motion. The hearing was on December 21, 2015, and draft proposed orders have been submitted to Judge Livingston’s staff attorney, but the order has not been signed and filed, as of the time I file this letter.
With the above-mentioned additions, Cross-Appellants’ updated request is that the following items be included in the Clerk’s supplemental record and transmitted to the Third Court of Appeals: 1. 6/4/2014 Plaintff’s Original Petition, Requests for Injunctive Relief and Request For Disclosure 2. 6/5/2014 Verification 3. 6/24/2014 Defendants’ Original Answer, Special Exceptions, Affirmative Defenses, Counterclaims, and Request For Disclosure 4. 7/15/2014 Plaintiff’s Notice of Trial Setting 5. 9/19/2014 Plaintiff’s Motion to Compel Discovery Responses Ms. Patricia Winkler Travis County Clerk’s Office Re: Cause No. D-1-GN-14-001701 December 28, 2015 Page 2 of 2 6. 9/19/2014 Plaintiff’s Motion to Compel Mediation 7. 9/22/2014 Jennifer Nichols and Nichols Photographers, Inc.’s Motion To Quash Deposition Of Jennifer Nichols 8. 9/22/2014 Jennifer Lindberg d/b/a Jennifer Lindberg Weddings’ Motion to Quash Deposition of Jennifer Lindberg 9. 9/23/2014 Plaintiff’s Amended Motion to Compel Discovery Responses 10. 9/25/2014 Defendants’ Response to Plaintiff's Motion to Compel Mediation 11. 9/26/2014 Defendants’ Response to Plaintiffs Motion to Compel Discovery Responses 12. 9/29/2014 Plaintiff’s Amended Motion to Compel Discovery Responses 13. 9/29/2014 Defendants’ Response to Plaintiff’s Response Motion to Compel Discovery Responses 14. 11/10/2015 Judgment Creditors’ Motion to Contest Judgment Debtors’ Affidavits and Statements of Net Worth and Sufficiency of Supersedeas Bonds 15. ??? Order on Judgment Creditors’ Motion to Contest Judgment Debtors’ Affidavits and Statements of Net Worth and Sufficiency of Supersedeas Bonds [yet to be signed by judge, as of noon Dec. 28, 2015] Please let me know the cost of obtaining the Clerk’s supplemental record and to whom I should make out the check, and I will promptly send payment.
Thank you.
Sincerely,
Craig Barker cc: The Gammon Law Office, PLLC, counsel of record for appellants, Champion Printing & Copying, LLC d/b/a Jerry Hayes Photography and Jerry Hayes, via ECF
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