ACCEPTED 05-19-00689-CV 05-19-00689-CV FIFTH COURT OF APPEALS DALLAS, TEXAS Appellate Docket Number o.5-19-o.o.689-CV 6/19/2019 12:03 PM LISA MATZ Appellate Case Style DOUGLAS DOYLE, ASHLEY DOYLE, MADISON DOYLE AND JOE PUTNAM. CLERK VS ROBIN CHRISTOPHER

Companion Case No.: FILED IN 5th COURT OF APPEALS DALLAS, TEXAS 6/19/2019 12:03:57 PM DOCKETING STATEMENT (Civil) LISA MATZ Amended/corrected statement Clerk Appellate Court: (to be tiled in the court of appeals upon perfection of appeal under TRAP 32) I. Appellant n. Appellant .-\ttoflley(s) ~ Person 0 Organization (choose one) KJ Lead Attorney First Name: JOE First Name: DOUGLAS Middle Name: Middle Name: Last Name: PUTNAM Last Name: Suffix: Law Firm Name: Suffix: Pro Se: Address 1:1425· W. Pioneer, Ste. 114 Address I: Address 2: Address 2: City: City: State: Texas·: Zip+4: 750.61 State: Texas Zip+4 Telephone: 972 259-2626 ext.

Telephone: ext. Fax: 972 254-1540.

Fax: ;::,nail: j oeputnam@earth1ink. net 1641700.0.

)Organization (choose one) Organization Name: First Name: First Name: ROB.IN c~"· Middle Name: Middle Name: Last Name: TORABI Last Name: CHRISTOPHER Suffix: Suffix: Law Firm Name: Pro Se: Address l: 1044,0., N. Central Expy., Ste 8 Address I: Address 2: Address j. City: City: State: Texas Zip+4: 75231 State: Texas Zip+4: Telephone: 972 200-7899 ext.

Telephone ext. Fax. 972 767-5017 .v.; Fax· Email: Emall SBN:240376o.5 Page 1 of7 Appellate Docket Number Appellate Case Style Vs

Companion Case No.:

Amended/corrected statement DOCKETING STATEMENT (Civil) Appel [ate Court: (to be filed in the court of appeals upon perfection of appeal under TRAP 32)

I. Appellant n.

IKI Person 0 Organization (choose one) o Lead Attorney First Name: First Name: MADTSClN Middle Name: Last Name: Middle Name: Last Name: Suffix: Law Firm Name: Suffix: Pro Se: Address I: Address I: Address 2: Address 2: City: City: State: Zip+4: State: Texas Zip+4 Telephone: ext.

Telephone: ext. Fax: Fax: email:

jOrganization (choose one) Lead Attorney Organization Name: First Name: First Name: Middle Name: Middle Name: Last Name: Last Name: Suffix: Suffix: Law Firm Name: Pro Se: Address 1: Address 1: Address 2: Address I' City: City: State: Texas Zip+4: State: Texas Zip+4: Telephone: ext.

Telephone ext. Fax: Fax: Email: Emai] SBN: Page 1 of 7 Appellate Docket Number.

Appellate Case Style Vs

Companion Case No.:

Amended/corrected statement. DOCKETING STATEMENT (Civil) Appellate Court: (to be tiled in the court of appeals upon perfection of appeal under TRAP 32)

L Appellant II. Appellant Attdrlley(s) rn Person 0 Organization (choose one) o Lead Attorney First Name: First Name: ASHLEY Middle Name: Middle Name: Last Name: Last Name: Suffix: Law Firm Name: Suffix: Pro Se: Address I: Address I: Address 2: Address 2: City: City: State: Texas State: Texas Zip+4 Telephone: ext.

Telephone: ext. Fax: Fax: email: Email: III. ,Appe o Person [Organization (choose one) Lead Attorney First Name: First Name: Middle Name: Middle Name: Last Name: Last Name: Suffix: Suffix: Law Firm Name: Pro Se: Address 1: Address 1: Address 2: Address 1: City: City: State: Texas Zip+4: State Texas Zip+4: Telephone: ext. 'Telephone, ext Fax.

Fax Email: Emai} SBN Page 1 of 7 Appellate Docket Number Appellate Case Style Vs

Companion Case No.:

Amended/corrected statement: DOCKETING STATEMENT (Civil) Appellate Court: (to be tiled in the court at appeals upon perfection of appeal under TRAP 32)

I. Appellant n. Appellant A-.(tOrlley(s) ~ Person 0 Organization (choose one) o Lead Attorney First Name: First Name: JOE Middle Name: Middle Name: Last Name: Last Name: Suffix: Law Firm Name: Suffix: Pro Se: Address 1: Address I: Address 2: Address 2: City: City: State: Texas State: Texas Zip+4 Telephone: ext.

Telephone: ext. Fax: Fax: email: Email:

Lead Attorney First Name: First Name: Middle Name: Middle Name: Last Name: Last Name: Suffix: Suffix: Law Firm Name: Pro Se: Address I: Address 1: Address 2: Address J' City: City: State' Texas Zip+4: State Texas Zip+4: ext. ::~ePhone: lelephone ext.

Fax Email I Emall.

Page 1 of 7 I _SBN Date order or judgment signed: Type of judgment: Date notice of appeal filed in trial court: Jt:l_;ne 1]; ~ 2.019 If mailed to the trial court clerk, also give the date mailed: Interlocutory appeal of appealable order: 0 Yes Kl No If yes, please specify statutory or other basis on which interlocutory order is appealable (See TRAP 28):

Accelerated appeal (See TRAP 28): DYes IXJ No If

Parental Termination or Child Protection? (See TRAP 28.4): DYes ~No Permissive? (See TRAP 28.3): DYes Iil No If yes, please specify statutory or other basis for such status:

Agreed? (See TRAP 28.2): DYes KJ No

Appeal should receive precedence, preference, or priority under statute or rule: DYes '[] No If yes, please

Does this case involve an amount under $100,000? IX] Yes ONo Judgment or order disposes of all parties and issues: U Yes DNa Apper 1 from final judgment: ~ Yes 0 No Does the appeal involve the constitutionality or the validitv of a statute, rule, or ordinance? [J Yes £JNo

Motion to Modify Judgment: DYes IRI No If yes, date filed: Request for Findings of Fact IKl Yes DNa If yes, date filed: May 1 and Conclusions of Law: Motion to Reinstate: DYes IKI No If yes, date filed: DYes [Xl No If yes, date filed: Malian under TRCP 306a: Other: DYes DNa

Affidavit filed in trial court: Contest filed in trial court: DYes iii No If yes, date filed: Date ruling on contest due:

Ruling on contest: 0 Sustained o Overruled Date of ruling: Page 2 of 7 IVIII. Bankruptcy Has any party to the court's judgment filed for protection in bankruptcy which might affect this appeal? DYes D No If yes, please attach a copy of the petition.

Date bankruptcy filed: Bankruptcy Case Number:

IX. Trial Court: County: Trial Court Clerk: 0 District 2(] County Trial Court Docket Number (Cause No.): Was clerk's record requested? XJ Yes D No If yes, date requested: June 11, 2019 Trial Judge (who tried or disposed of case): If no, date it will be requested: First Name: BRENDA Were payment arrangements made with clerk?

Middle Name: UYes ONo Dlndigent Last Name: (Note: No request required under TRAP 34.S(a),(b» Suffix: Address 1:120)1"Ettit<St., Ste 2400:...A Address 2 : City: Dallas State Texas 75270 Telephone: Fax: Email:

Reporter's or Recorder's Record: Is there a reporter's record? ~Yes D No Was reporter's record requested? fXJYt;S ONo Was there a reporter's record electronically recorded? 0 Yes 0 No If yes, date requested: If no, date it will be requested: Were payment arrangements made with the court reporter/court recorder? U Yes 0 No Dlndigent

Page 3 of 7 fiJ Court Reporter o Court Recorder o Official o Substitute First Name: Middle Name: Last Name: GALINDO Suffix: Address I: 1201.:m:trn se :, Ste. 2400-A Address 2: City State: Zip + 4: Telephone: ext Fax' Email: j ackiegalindo@dallascounty. org X. Supersedeas BO'rid Supersedeas bond filed: 0 Yes 0 No If yes, date filed: Will fiJr:: ~ Yes 0 No XI. Extraordinary R~Her Will you request extraordinary relief'{e.g. temporary or ancillary relief) from this Court? 0 Yes Kl No If yes, briefly state the basis for your request:

~ir, ·4Jternijtl~~~~.'" ," Gth, 8th, 9th, lOth, 11th, nth, 13(h Or 14th Court9cA-p. h

Should this appeal be referred to mediation?

DYes I]g No If no, please Has the case been through an ADR procedure? DYes [Xl No If yes, who was the mediator?

What type of ADR procedure?

At what stage did the case go through ADR? D Pre-Trial D Post-Trial D Other If other, please specify: Type of case?

Give a brief description of the issue to be raised on appeal, the relief sought, and the applicable standard for review, if known (without prejudice to the right to raise additional issues or request additional relief):

I How was the case disposed of?

I Summary of reliefgranted, including amount of money judgment, and if any, damages awarded, Ilf money Judgment, what was the amount? Actual damages: I Punitive (or similar) damages: Page 4 of 7 fAttorney'S fees (trial) $6,148.50 Attorney's fees (appellate): Other If other. please specify:

Will you challenge this Court's jurisdiction? DYes [iJ No Does judgment have language that one or more parties "take nothing"? 0 Yes fJ No Does judgment have a Mother Hubbard clause? DYes IRl No Other basis for finality? Disposition of issue in cont r over-sy Rate the complexity of the case (use I for least and 5 for most complex): DID 2 KJ 3 0 4 0 5 Please make my answer to the preceding questions known to other parties in this case. DYes 0 No Can the parties agree on an appellate mediator? 0 Yes 0 No If yes, please give name, address, telephone, fax and email address: Name Address Telephone Fax Email

Languages other than English in which the mediator should be proficient: Name of person filing out mediation section of docketing statement:

XIII. Related Matters List any pending or past related appeals before this or any other Texas appellate court by court, docket number, and style.

Docket Number: Trial Court: Style: Vs.

Page 5 of7 IXIV,--p~~B~-no Program: (Complete section if filing inthe 1st, 3rd,Sth, or 14th Courts of App-eals) e Courts of Appeals listed above, in conjunction with the State Bar of Texas Appellate Section Pro Bono Committee and local Bar sociations are conducting. a program to place a limited number of civil appeals with appellate counsel who will represent the appe llz appeal before th IS Court The Pro Bono Committee is solely responsible for screening and selecting the civil cases for inclusion in the Program based upon a nun discretionary criteria, including the financial means of the appellant or appellee, Ifa case is selected by the Committee, and can be mat with appellate counsel, that counsel will take over representation of the appellant or appellee without charging legal fees More inform: regarding this program can be found in the Pro Bono Program Pamphlet available in paper form at the Clerk's Office or on the Internet; www tex-app.org If your case is selected and matched with a volunteer lawyer, you will receive a letter from the Pro Bono Committee thirty (30) to forty-five (45) days after submitting this Docketing Statement.

Note there IS no guarantee that if you submit your case for possible inclusion in the Pro Bono Program, the Pro Bono Committee will SI your case and that pro bono counsel can be found to represent you, Accordingly, you should not forego seeking other counsel to repres. in this proceeding By signing your name below, you are authorizing the Pro Bono committee to transmit publicly available facts and information about your case, including parties and background, through selected Internet sites and Listserv to its pool of volunteer appel attorneys Do you want this case to be considered for inclusion in the Pro Bono Program? DYes [j.No Do you authorize the Pro Bono Committee to contact your trial counsel of record in this matter to answer questions the committee may f regarding the appeal? 0 Yes 0 No Please note that any such conversations would be maintained as confidential by the Pro Bono Committee and the information used solei' the purposes of considering the case for inclusion in the Pro Bono Program, ' If you have not previously filed an affidavit ofIndigency and attached a file-stamped copy of that affidavit, does your income exceed 201 the Ll.S. Depa.trnent of Health and Human Services Federal Poverty Guidelines? [l Yes 0 No These guidelines can be found in the Pro Bono Program Pamphlet as well as on the internet at http://asDe.hhs.~ov/Doverty/06poverty.sht Are you willing to disclose your financial circumstances to the Pro Bono Committee? 0 Yes '0 No If yes, please attach an Affidavit of Indigency completed and executed by the appellant or appellee, Sample forms may be found in the C Office or on the internet at http://www,tex-app.org. Your participation in the Pro Bono Program may be conditioned upon your executioi an affidavit under oath as to your financial circumstances.

Give a brief description of the issues to be raised on appeal, the relief sought, and the applicable .tar.dard of rev iew, if known <without prejudice to me right to raise additional issues or request additional r.'k:f; use" separate attachment, if ne.',:::~ary).

XV. Signature

Date: G,- ('l-{C(

Printed Name: State Bar No l & ~t '1 {?(l.l J OS fhrtv~~ Electronic Signature (Optional) ~

Page 6 of 7 The undersigned counsel certifies that this docketing statement has been served on the following lead counsel for all parties to the trial court's order or judgment as follows on

Electronic Signature: (Optional) State Bar No.: Person Served MARK TORABI Certificate of Service Requirements (TRAP 9.S(e)): A certificate of service must be signed by the person who made the service and must state: (I) the date and manner of service; (2) the name and address of each person served, and (3) if the person served is a party's attorney, the name of the party represented by that attomey

Please enter the following for each person served:

Date Served: Manner Served: First Name: Middle Name: Last Name: TORABI Suffix: Law Firm Name: Address I' Address 2: City: State Telephone: Fax: 97'1. 967=StH7 Email: If Attorney, Representing Party's Name: i'ROBIN CHRISTOPHER ------~--~~~~-------------------------------------

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