Harbor America Central, Inc. v. William Reeves

ACCEPTED 15-24-00128-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 2/24/2025 10:47 AM No. 15-24-00128-CV CHRISTOPHER A. PRINE CLERK FILED IN IN THE COURT OF APPEALS 15th COURT OF APPEALS FOR THE FIFTEENTH DISTRICT OF TEXAS AUSTIN, TEXAS AUSTIN, TEXAS 2/24/2025 10:47:25 AM CHRISTOPHER A. PRINE Clerk HARBOR AMERICA CENTRAL, INC., Appellant, v. WILLIAM REEVES, Appellee.

On Appeal from the 55th District Court of Harris County, Texas Trial Court No. 2017-25574

JOINT MOTION TO VACATE AND REMAND AND TO EXPEDITE MANDATE PURSUANT TO SETTLEMENT TO THE HONORABLE COURT OF APPEALS: This Court abated the appeal on January 30, 2025. Since then, Appellant Harbor America Central, Inc., and Appellee William Reeves have finalized their settlement agreement.

Under Texas Rule of Appellate Procedure 42.1(a)(2), the parties on both sides ask this Court to reinstate the appeal, set aside the trial court’s judgment without regard to the merits, and remand the case to the trial court for rendition of a take- nothing judgment in accordance with the parties’ agreement.

Further, under Texas Rule of Appellate Procedure 18.1(c), the parties respectfully request that the Court issue its mandate immediately so the parties may move forward expeditiously with their settlement in the trial court.

Respectfully submitted, THE GEORGE LAW FIRM PLLC BECK REDDEN LLP By: /s/ David George By: /s/ Joshua S. Smith David George Joshua S. Smith Texas Bar No. 00793212 State Bar No. 24093173 Louisiana Street, Suite 900 [email protected] Houston, Texas 77002 Russell S. Post Telephone: (713) 857-2280 State Bar No. 00797258 [email protected] [email protected] 1221 McKinney Street, Suite 4500 Houston, Texas 77010 THE BUZBEE LAW FIRM Telephone: (713) 951-3700 Anthony G. Buzbee ATTORNEYS FOR APPELLANT, Texas Bar No. 24001820 HARBOR AMERICA CENTRAL, INC. [email protected] Chris J. Leavitt State Bar No. 24053318 [email protected] Lionel Sims III Texas Bar No. 24107465 [email protected] J.P. Morgan Chase Tower Travis, Suite 7500 Houston, Texas 77002 Telephone: (713) 223-5393 Facsimile: (713) 223-5909 www.txattorneys.com ATTORNEYS FOR APPELLEE, WILLIAM REEVES

CERTIFICATE OF SERVICE I hereby certify that on February 24, 2025 a true and correct copy of the foregoing motion has been electronically filed and served on all counsel.

/s/ Joshua S. Smith Joshua S. Smith

Automated Certificate of eService This automated certificate of service was created by the efiling system.

The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Jesse Crochet on behalf of Joshua Smith Bar No. 24093173 [email protected] Envelope ID: 97703836 Filing Code Description: Motion Filing Description: Joint Motion to Vacate and Remand and to Expedite Mandate Pursuant to Settlement Status as of 2/24/2025 10:54 AM CST Associated Case Party: Harbor America Central, Inc. Name BarNumber Email TimestampSubmitted Status Russell S.Post [email protected] 2/24/2025 10:47:25 AM SENT Joshua S.Smith [email protected] 2/24/2025 10:47:25 AM SENT

Associated Case Party: William Reeves Name BarNumber Email TimestampSubmitted Status Ryan Pigg 24088227 [email protected] 2/24/2025 10:47:25 AM SENT Thomas Holler 24126898 [email protected] 2/24/2025 10:47:25 AM SENT William DavidGeorge [email protected] 2/24/2025 10:47:25 AM SENT Lionel Sims 24107465 [email protected] 2/24/2025 10:47:25 AM SENT Anthony G.Buzbee [email protected] 2/24/2025 10:47:25 AM SENT Chris J.leavitt [email protected] 2/24/2025 10:47:25 AM SENT Anthony Buzbee 24001820 [email protected] 2/24/2025 10:47:25 AM ERROR