Robert Edward Battaile v. Texas Elections Division, Hon. Jane Nelson; Texas Secretary of State; Jeffrey Travillion, Travis County Commissioner

ACCEPTED 15-25-00142-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 10/20/2025 12:00 AM CAUSE NO. 15-25-00142-CV CHRISTOPHER A. PRINE CLERK FILED IN IN THE FIFTEENTH COURT OF APPEALS 15th COURT OF APPEALS AUSTIN, TEXAS 10/20/2025 12:00:00 AM AUSTIN, TEXAS CHRISTOPHER A. PRINE Clerk

ROBERT EDWARD BATTAILE, Appellant Pro Se v.

STATE OF TEXAS ELECTIONS DIVISION, et al., Appellees

SUPPLEMENT TO LETTER CLARIFYING NUMBER OF DEFENDANTS

TO THE HONORABLE JUSTICES OF THE FIFTEENTH COURT OF APPEALS:

Appellant files this supplement to his October 17, 2025 Letter to the Court described as “Letter re wrong number of Defendants in Court Order” to provide concise clarification regarding the actual structure of the parties named in this matter.

–1– 15-25-00142-CV The Court’s October 16 Order referenced “approximately forty-two defendants.” That figure is not accurate when considered in legal context.

Each set of individuals was named in official capacity only and represents a single governmental or corporate entity. When grouped by entity, there are eighteen (18) distinct defendant entities or real parties in interest, summarized below:

1. State of Texas – Ken Paxton (Attorney General); Jane Nelson (Secretary of State) – Official capacities for ignoring election fraud and suppressing FOIA requests re: Election Investigation. Also re Jail conditions and ending statewide Courts of No Record that lack due process and transparency.

2. Travis County – Commissioners Travillion, Howard, Shea, Gómez, and Judge Brown; Sheriff Sally Hernandez; County Attorney Dyana Mercado; right of first refusal for city to purchase Clayton Vocational Institute (county-owned historic property).

Also for ignoring Election Coercion issues; ignoring “Public Health and Safety” bogus claims used to breach contract with –2– 15-25-00142-CV Austin Bocce League; ignoring Cemetery Desecration and Police Misconduct.

3. CapMetro – Capital Metropolitan Transportation Authority – quasi-governmental transit authority under Travis County oversight. Deceptive trade practice during approval process by not disclosing they would be charging for but not running on weekends. Commissioner Travillion is Chairman of the Board.

4. City of Manor – Mayor Harvey; six Council Members; City Manager Leslie Moore; City Secretary Lluvia Almaraz; Public Works Director; former Heritage & Tourism Manager; Police Chief Phipps, officers and two former officers. Election Coercion and numerous claims of police misconduct and coverups, civil rights violations, historic destruction of landmarks, allowing parkland thefts of land and money; plus retaliation and false imprisonment. City has been operating without a legal Council quorum since November election fraud.

–3– 15-25-00142-CV 5. Freese & Nichols, Inc. – Authors of the faulty Comprehensive Plan used to destroy historic Manor, and for never holding the town hall meetings or finishing the project they were paid for.

6. Legacy Performance Capital LLC – Developer of townhomes on historic 1906 Martin McVey Cemetery site including misuse of city funds to clear land and desecrating said cemetery.

7. Las Entradas Development LLC – Developer of the 1840's James B Manor Homestead tract linked to the Col. Eppright estate, and need to protect remaining fragile shacks.

8. Manor MF LLC – Developer of apartments on the James B.

Manor Homestead tract purchased from Las Entradas. Plaintiff sought emergency injunctive relief to protect the historic site, but Judge Soifer prevented the filing or consideration of Plaintiff’s ex parte application for a Temporary Restraining Order (TRO), allowing demolition and site work to proceed despite pending preservation concerns.

–4– 15-25-00142-CV 9. Maqil Inc. – Seeking zoning changes for Manor Grocery site inconsistent with historic Main Street; alleged false PO Box and misrepresentation on zoning filings.

10. Manor ISD – Owner of historic school property (former Parson’s School for Girls / Masonic Lodge #222) that is currently an abandoned school. Right of first refusal sought.

11. Buildblock.io – Developer of overpowering live-work-play apartments/offices inconsistent within the Historic District.

12. Carlos Moyeda – Demolition of historic mansion at 104 E.

Townes Street; and future building approvals/restrictions.

13. 13100 FM 973 Manor Crossing shopping center for Chapter violations – Includes (a) HEB – Plaza obligation; (b) Park at Manor Crossing Apartments – parkland fee violations; (c) Manor Retail GP – sales tax and public space obligations.

14. Meritage Homes of Texas LLC – ShadowGlen development; unpaid parkland fees, parkland dedication and trail installs.

–5– 15-25-00142-CV 15. Manor Commons LLC – Retail mixed-use project over ten acres with unfulfilled plaza requirement.

16. Dalfen Industrial / DG Manor Downs LP – Industrial park replacing historic Manor Downs racetrack, destroying heritage trees, environmental issues, traffic mitigations and needless 380 grants claimed as “incentives” worth millions of dollars.

17. Texas A&M Foundation – Initially a record custodian; treated as Defendant pending full compliance with Public Information Act requests regarding Homestead and Eppright tracts.

18. Travis Central Appraisal District (TCAD) – Non-party resource for property records and agricultural-use exemptions.

Appellant further clarifies that certain non-defendant parties appear in the record for context and standing purposes.

• Bobby Reese, submitted to be a candidate for Manor City Council but was unlawfully prevented from appearing on the ballot—an event central to Appellant’s Election Contest and claims of election coercion, voter disenfranchisement, and ultra vires conduct by state and municipal officials.

–6– 15-25-00142-CV • Austin Bocce League, a nonprofit organization operated by Appellant, appears as a contractual and equitable claimant in relation to the City of Manor’s breach of its Licensing Agreement, implied park-improvement commitments and failure to provide designated public recreation space.

These parties are included for factual context and standing, but they are not defendants in the underlying cause. Their interests illustrate the public-trust and contractual dimensions of this litigation.

Appellant respectfully submits that, although more than forty individual names appear throughout the pleadings, these individuals operate within the eighteen (18) discrete entities identified above. Each entity functions as the real party in interest for service, liability, and appellate review. The earlier reference in the Court’s order to “approximately forty-two defendants” therefore misstates the operative structure of the case.

This clarification is filed while the Court retains plenary authority under Texas Rule of Appellate Procedure 19.1 to correct clerical and factual errors for accuracy in the record. This is a best efforts summary not intended to limit any impacts that may have been inadvertently omitted in error.

–7– 15-25-00142-CV Respectfully submitted on October 18, 2025 by /s/ Robert Edward Battaile Robert Edward Battaile, Appellant Pro Se E. Eggleston St., Unit B Manor, Texas 78653 512-662-2955 [email protected]

CERTIFICATE OF SERVICE I certify that on October 18, 2025, a true and correct copy of this Supplement was served via e-service through the eFileTexas system on all counsel and parties of record / appellees / defendants, including by mail to Dalfen Industries, and Texas A&M Foundation.

Maqil Inc furnished incorrect address information to TCAD and cannot be noticed at present. Appellant has filed Public Information Request PIR-264- 2025 with City of Manor for the owner's accurate information and has emailed Manor Grocery owner's Project Designer, Chris Garcia [email protected] in an attempt to gather this information.

/s/ Robert Edward Battaile Robert Edward Battaile, Appellant Pro Se

–8– 15-25-00142-CV 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.

Envelope ID: 107015646 Filing Code Description: Other Document Filing Description: SUPPLEMENT TO LETTER CLARIFYING NUMBER OF DEFENDANTS Status as of 10/20/2025 7:03 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jeffrey Hobbs 24012837 [email protected] 10/18/2025 6:44:31 PM SENT Michael Kabat 24050847 [email protected] 10/18/2025 6:44:31 PM SENT Joanna Salinas 791122 [email protected] 10/18/2025 6:44:31 PM SENT William Davidson 5447000 [email protected] 10/18/2025 6:44:31 PM SENT Gavin Villareal 24008211 [email protected] 10/18/2025 6:44:31 PM SENT Michael Roberts 24082153 [email protected] 10/18/2025 6:44:31 PM SENT Cynthia Veidt 24028092 [email protected] 10/18/2025 6:44:31 PM SENT Stephanie Serrano 24092655 [email protected] 10/18/2025 6:44:31 PM SENT Kevin O'Hanlon 15235500 [email protected] 10/18/2025 6:44:31 PM SENT Patrick Kelly 11228000 [email protected] 10/18/2025 6:44:31 PM SENT Tyler Ryska 24096597 [email protected] 10/18/2025 6:44:31 PM SENT Austin Jones 24116579 [email protected] 10/18/2025 6:44:31 PM SENT William Duncan 24124453 [email protected] 10/18/2025 6:44:31 PM SENT Roy Adams [email protected] 10/18/2025 6:44:31 PM SENT Tristan AGarza [email protected] 10/18/2025 6:44:31 PM SENT Lauren Bush 24142742 [email protected] 10/18/2025 6:44:31 PM SENT Anna Puff 24144206 [email protected] 10/18/2025 6:44:31 PM SENT Edward Smith 24037790 [email protected] 10/18/2025 6:44:31 PM SENT Robert EdwardBattaile [email protected] 10/18/2025 6:44:31 PM SENT Annette Bittick [email protected] 10/18/2025 6:44:31 PM SENT Patricia Muniz [email protected] 10/18/2025 6:44:31 PM SENT Raylynn Howell [email protected] 10/18/2025 6:44:31 PM SENT 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.

Envelope ID: 107015646 Filing Code Description: Other Document Filing Description: SUPPLEMENT TO LETTER CLARIFYING NUMBER OF DEFENDANTS Status as of 10/20/2025 7:03 AM CST Case Contacts Raylynn Howell [email protected] 10/18/2025 6:44:31 PM SENT Kim McBride [email protected] 10/18/2025 6:44:31 PM SENT Lea Ohrstrom [email protected] 10/18/2025 6:44:31 PM SENT Sneed Vine &Perry [email protected] 10/18/2025 6:44:31 PM SENT Stormy Downing [email protected] 10/18/2025 6:44:31 PM SENT Andy Soule [email protected] 10/18/2025 6:44:31 PM SENT Karah Powers [email protected] 10/18/2025 6:44:31 PM SENT Martha AnnAdams [email protected] 10/18/2025 6:44:31 PM SENT Benjamin C. Hunt [email protected] 10/18/2025 6:44:31 PM SENT Eldridge Burns [email protected] 10/18/2025 6:44:31 PM SENT Amy Botelho [email protected] 10/18/2025 6:44:31 PM SENT Carol Shipley [email protected] 10/18/2025 6:44:31 PM SENT Emily Hill [email protected] 10/18/2025 6:44:31 PM SENT Anne Weir [email protected] 10/18/2025 6:44:31 PM SENT