Texas Court of Appeals, 15th District, 2025

Dominique Reed and Dakota Hill v. Cypress Creek at South Cedar

Texas Court of Appeals, 15th District · Decided November 21, 2025

Opinion

ACCEPTED 15-25-00197-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 11/21/2025 12:49 PM IN THE FIFTEENTH COURT OF APPEALSCHRISTOPHER A. PRINE CLERK FILED IN 15th COURT OF APPEALS NO. 15-25-00197-CV AUSTIN, TEXAS 11/21/2025 12:49:55 PM DOMINIQUE REED AND DAKOTA HILL, Appellants CHRISTOPHER A. PRINE Clerk v. CYPRESS CREEK AT SOUTH CEDAR, Appellee ―――――――――――――――――――――――――――――――――――――――――――――――――― On Appeal from County Court at Law No. 1 of Bell County Trial Court No. 25CCV01420 Hon. Paul A. Motz, Presiding ―――――――――――――――――――――――――――――――――――――――――――――――――― EMERGENCY NOTICE OF EXECUTION OF WRIT OF POSSESSION AND EXTREME URGENCY

TO THE HONORABLE JUSTICES OF THE FIFTEENTH COURT OF APPEALS:

Appellants Dominique Reed and Dakota Hill file this EMERGENCY NOTICE to inform the Court that the Writ of Possession is now actively being executed, with eviction scheduled for tomorrow, November 22, 2025, at 11:20 AM.

I. IMMINENT IRREPARABLE HARM 1. Writ Executed: The FINAL WARNING OF EVICTION was posted on the premises on November 21, 2025, at 11:20 AM, by the Bell County Sheriff's Office.

2. Harm is Irreversible: The imminent eviction will render Appellants homeless for the second time in one year. This catastrophic harm, which includes the displacement of a minor child, cannot be remedied by any subsequent legal or monetary judgment.

3. Judicial Causation: The current crisis is not due to Appellants' lack of funds or diligence.

The crisis is caused solely by the District Court’s failure to act on Appellants’ multiple emergency motions to release the readily available Court Registry Funds $10,493.33 equity funds (Exhibit A) necessary to maintain the appellate stay and prevent this irreparable life altering harm.

II. MANDATORY APPELLATE INTERVENTION The District Court's failure to take the matter seriously constitutes an abuse of discretion that directly caused the execution of the writ, forcing Appellants into homelessness.

Appellants have provided evidence demonstrating:

● Funds are sufficient and available (Exhibit A).

● Diligent attempts to access funds were made (Exhibit C).

● The District Court refused to rule timely (Exhibit F).

● The underlying eviction judgment is jurisdictionally void (Section II.( -C) of Emergency Motion For Reconsideration Of November 19, 2025 Order And Motion To Reinstate Appellate Stay Under Tex. R. App. P. 29.3 And 24.4(C) Motion).

Appellants pray that the Court will immediately review the concurrently filed Emergency Motion for Reconsideration and use its equitable powers to issue an Order of Abatement and reinstatement of the appellate stay to prevent the appeal from being rendered moot and to prevent this irreparable harm.

Respectfully Submitted,

/s/ Dominique Reed

Dominique Reed, Pro Se

/s/ Dakota Hill

Dakota Hill, Pro Se

CERTIFICATE OF SERVICE I hereby certify that on November 21, 2025, a true and correct copy of this EMERGENCY NOTICE OF EXECUTION OF WRIT OF POSSESSION AND EXTREME URGENCY was served via electronic filing upon all counsel of record for Appellee, CYPRESS CREEK AT SOUTH CEDAR.

/s/ Dominique Reed

Dominique Reed, Pro Se

/s/ Dakota Hill

Dakota Hill, Pro EXHIBIT (A) COVER SHEET

NO. 15-25-00197-CV IN THE FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS DOMINIQUE REED AND DAKOTA HILL, Appellants v. CYPRESS CREEK AT SOUTH CEDAR, Appellee

APPELLANTS’ EXHIBIT A A WRIT OF POSSESSION HAS BEEN ISSUED FOR YOU TO VACATE THE PREMISES.

THIS WRIT MAY BE EXECUTED AT ANY TIME ON OR AFTER THE SPECIFIED DATE.

THIS IS YOUR FINAL WARNING TO VACATE THESE PREMISES WITHIN 24 HOURS FROM THE DATE OF THIS NOTICE.

FAILURE TO VACATE THESE PREMISES WILL RESULT IN ALL PERSONAL PROPERTY BEING REMOVED AND PLACED CURBSIDE.

THE REMOVAL OF YOUR PERSONAL PROPERTY WILL BE EFFECTED WITH OR WITHOUT YOUR PRESENCE.

EXHIBIT (C) COVER SHEET

NO. 15-25-00197-CV IN THE FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS DOMINIQUE REED AND DAKOTA HILL, Appellants v. CYPRESS CREEK AT SOUTH CEDAR, Appellee

APPELLANTS’ EXHIBIT C FILED SEPTEMBER 15, 2025- JUDGE DENIED MOTION MOVANT DOMINIQUE REED'S EMERGENCY EX PARTE MOTION FOR TEMPORARY RELIEF AND MOTION TO SEAL ADDRESS

FILED OCTOBER 24, 2025- NO RESPONSE FROM COURT AFTER EMAILS EMERGENCY MOTION FOR PARTIAL DISTRIBUTION OF FUNDS FROM RECEIVERSHIP ESTATE.

FILED NOVEMBER 17, 2025 - NO RESPONSE FROM COURT PRIOR TO NOVEMBER 20, 2025 ORDER GRANTING SUBMISSION AND AUTHORIZING IMMEDIATE RULING ON SUPPLEMENTAL EMERGENCY MOTION TO WITHDRAW PARTIAL FUNDS FROM COURT REGISTRY

FILED NOVEMBER 19, 2025- NO RESPONSE FROM COURT PRIOR TO NOVEMBER 20, 2025 NOTICE OF ADVERSE APPELLATE RULING AND RENEWED REQUEST FOR EMERGENCY ORDER INSTANTER NO. 23DFAM337543 IN THE MATTER OF THE IN THE DISTRICT CQURT MARRIAGE OF 146TH JUDICIAL DOMINIQUE AC REED DISTRICT AND BELL COUNTY, TEXAS CARL LEE HILL MOVANT DOMINIQUE REED'S EMERGENCY EX PARTE MOTION FOR TEMPORARY RELIEF AND MOTION TO SEAL ADDRESS TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, DOMINIQUE REED ("Movant"), representing herself pro se, and files this Emergency Ex Parte Motion for Temporary Relief and Motion to Seal Address. In support, Movant respectfully shows the Court the following:

I. INTRODUCTION

1. Movant seeks narrowly tailored, emergency ex parte relief to prevent immediate and irreparable harm. Movant and her daughter face imminent eviction and homelessness due to an inability to post the required $897.00 appeal bond. These funds are available from the proceeds of the sale of the marital residence, which are currently held by a court- appointed Receiver. Without an immediate order from this Court releasing these funds, Movant will lose her right to appeal the eviction, resulting in catastrophic harm for which there is no adequate remedy at law.

Copy from re:SearchTX 2. Additionally, Movant, a participant in the Texas Address Confidentiality Program (ACP), seeks an immediate order to seal her physical address, which was improperly disclosed in public filings in the separate eviction proceeding. Given the history of family violence in this case, this disclosure presents an immediate and ongoing threat to the safety of Movant and her daughter.

Il. FACTUAL BACKGROUND 3. Movant and Respondent were married for 16 years. The marriage was marked by family violence and cruelty committed by Respondent. On December 16, 2022, Respondent committed an act of family violence that resulted in criminal charges. Respondent ultimately entered a plea and received deferred adjudication for family violence on November 8, 2024, with the case being dismissed on Februar 6, 2025. y 4. The daughter of the marriage has chosen not to have contact with her father, the Respondent, since November of 2023, due to his emotional cruelty, and abusive behavior.

5. Respondent abandoned the marital residence. While Respondent continued to pay household bills which also included a majority of his own obligations he denied nearly every additional request for support for Movant or their daughter, leaving them without meaningful support and forcing them into financial instability. During the pendenc of y the divorce, Respondent engaged in a pattern of coercive financial control, including misrepresenting and concealing community assets such as a 401(k), investment account s, and a bank account titled in his sole name opened during the marriage into which community property paychecks were deposited.

6. Shortly after being summoned in his criminal family violence case, Respond ent initiated retaliatory civil proceedings against Movant, seeking the appoint ment of a receiver to

Copy from re:SearchTX force the sale of the marital home. This action was designed to strip Movant of her remaining equity and leave her without the financial means to secure housing.

7. The Court ordered Movant and her daughter to vacate the marital residence by December 1, 2024, leaving them without stable housing ultimate ly rendering them homeless for over five months until Movant was able to secure housing May 9", 2025. Shortly after our daughter of the marriage graduate d high school and court ordered child support ended June, 2025 this left the Movant and daughter unable to fully stabilize financially after being homeless.

8. On August 15, 2025, the court-appointed Receiver completed the sale of the marital residence. The proceeds from that sale are currently under the Receiver's control.

9. Movant and her 18-year-old daughter, who is listed as a tenant on their current lease, now face imminent eviction. To perfect an appeal of this eviction, Movant must post a bond of $897.00 with the Justice Court by September 15", 2025 by 5:00pm. Movant has no other funds available to post this bond.

10. Movant and her daughter are participants in the Texas Address Confidentiality Program due to the history of family violence.

Despite this, their current physical address has been publicly filed in the eviction case, creating a significant and immediate safety risk.

Hl. ARGUMENT AND AUTHORITIES A. Emergency Release of Funds to Prevent Irreparab Harm le 10. A court may grant temporary relief to preserve the status quo and prevent irreparable harm pending a final resolution. In re Newton, 146 S.W.3d 648, 651 (Tex. 2004).

Irreparable harm is an injury for which the injured party cannot be adequately compensated by damages. Here, the harm is clear: without an immediate order releasing the $897 for the appeal bond, Movant and her daughter face homelessness. An eviction

Copy from re:SearchTX on their record will create a severe, long-term barrier to securing future housing. This is not an injury that can be remedied by monetary damages after the fact.

11. A court has the inherent authority to issue equitable relief to protect a litigant's fundamental right to appeal. In re Smith, 1 92 S.W.3d 564, 568 (Tex. 2006) (recognizing a court's authority to protect a party's rights pending appeal). The funds to prevent this harm are available and under the control of the Court's appointed Receiver. The relief requested is narrowly tailored to release only the amount necessary to preserve Movant's rights and prevent the immediate and irreparable harm of homelessness.

B. Sealing Address is Necessary for Safety 12. The public disclosure of the physical address of a survivor of family violence constitutes an immediate threat of irreparable harm. Movant and her daughter are participants in the Texas Address Confidentiality Program, which is designed to protect them from such risks.

13. Pursuant to the Texas Rules of Civil Procedure and Texas Government Code, a court may order filings sealed to prevent a specific, serious, and substantial interest which clearly outweighs any presumption of openness. Tex. R. Civ. P. 76a; Tex. Gov't Code § 58.052.

The physical safety of a party and her child, particula rly in a case with a documented history of family violence, is precisely the kind of interest these rules are meant to protect. Movant requests that the Court seal all filings containing the Movants physical address and order that all ACP substitute address be used in all future filings.

IV. REASONS JUSTIFYING EX PARTE RELIEF 14. This Motion is brought on an ex parte basis because Movant will suffer immedia te and irreparable injury before the adverse party can be heard in opposition. The deadline to

Copy from re:SearchTX post the eviction appeal bond is imminent. Any delay will result in the loss of Movant's right to appeal and will lead directly to homelessness for her and her daughter.

15. Furthermore, notice should not be required because of the history of retaliato ry litigation and coercive control exhibited by the Respond ent. Providing notice of this specific request for funds could prompt Respondent to take actions to obstruct or interfere with the Receiver's ability to promptly comply with the Court's order, thereby frustrating the purpose of this emergency motion. Given the safety concerns, ex parte relief is also necessary to allow the Court to seal Movant's address before Respondent has an opportunity to further disseminate it.

V. PRAYER WHEREFORE, PREMISES CONSIDERED, Movant Dominique Reed respectfully prays that this Court immediately:

1. GRANT this Emergency Ex Parte Motion; 2. ORDER the court-appointed Receiver to immediately release $897.00 from the proceeds of the sale of the marital residence and direct those funds to the Justice Court 1 court registry as to serve as the bond for Movant's eviction appeal deadline today Septemb er 15", 2025 by 5:00pm.

3. ORDER the Bell County District Clerk to immediately seal all current and future filings that contain Movant's physical address and replace it with her Address Confidentiality Program (ACP) substitute address; and 4. GRANT Movant such other and further relief, at law or in equity, to which she may be justly entitled.

Respectfully Submitted,

Dominiaue AC Reed Copy from re:SearchTXAD SE Notice to Defendant of Requirements upon filing Pauper's Affidavit

Cause #11CV2501103

To Dominique Reed, Dakota Hill, Defendant

Amount of Rent that must be paid into the Justice Court Registry: $ 897.00 by the 15th day of September, 2025.

Rule 506.1(e), Texas Rules of Civil Procedure.

FAILURE TO PAY THE REQUIRED AMOUNT INTO THE JUSTICE COURT REGISTRY BY THE DATE PRESCRIBED BY SUBDIVISION (3) MAY RESULT IN THE COURT ISSUING A WRIT OF POSSESSION WITHOUT A HEARING.

(initial) I hereby acknowledge the receipt of my Notice to deposit rent into the egistry/of the court.

(initial) I understand in the event that I fail to deposit the rent into the registry of the cou rt that a Writ of Possession may bei SSueE

Date: 3 bAD Signa re:

"ry

Copy from re:SearchTX Cause # 11CV2501103 Cypress Creek at South Cedar § IN THE JUSTICE COURT Plaintiff VS PRECINCT ONE §

Dominque Reed, Dakota Hill and all other occupants § Defendant BELL COUNTY, TEXAS FINAL JUDGMENT This the 2nd day of September, 2025, being the appearance date of the Defendant, Dominque Reed, Dakota Hill, and the Court being regularly in session in term time at the place where the above-styled and numbered cause was commenced, in which cause Cypress Creek at South Cedar is Plaintiff, represented by attorney Doreen Wagner and Dominque Reed, Dakota Hill is Defendant; and came the parties in person, and by attorney, and announced ready for trial; and neither party having demanded jury. all matters in controversy of fact and of law were submitted a to the Court; and the pleadings, evidence and arguments of the parties having been heard, the Court finds that the Plaintiff, Cypress Creek at South Cedar, should have possession of the premises described in Plaintiff's petition, and the Court further finds that Plaintiff should recover for cost and rent and assesses his damages therefore at $2,405.51.

IT, IS THEREFORE, ADJUDGED AND DECREED by the Court that the said Plaintiff, Cypress Creek at South Cedar, have restitution of the said premises, for which let Writ of Possession issue, to wit: South Cedar Rd #11208 Temple. Tx. 76502 and further that Plaintiff do have and recover of and from said Defendant the sum of $2,226.51 as rent, with interest thereon from date at the rate of 7.50 % per annum, attorney fees in the amount of $0.00 and court cost in the amount of $179.00, for which let execution issue.

Appeals to be filed with the court on or before 8th day of September, 2025, Defendant's appeal bond set at $3,481.51, with monthly rentals paid into the registry of the County Court p the appeal in the amount of $897.00 monthly :

Signed this the 2nd day in : «Theodore R. Duffield of the Peace, Precinct f Justice Bell : : County Texas it you are an individual (not a com ney or property may be protected from being taken to pay this judgment. Find out more by visiting www..texaslaw help.g/exempt- property / Si usted es una persona fisica (vy no una compafiia) su dinero 0 propiedad pudieran estar protegidos de ser embargados como pago de esta deuda decretada en juicio en contra suya, Obtenga mavor informacion visitando el sitio www.texaslawhelp.org/exempt-p roperty.

You may appeal this judgment by filing a bond, making a cash deposit, or filing a Statement of Inability to Afford Payment of Court Costs within 5 days after this judgment was signed. See Texas Rule ofCivil Procedure 510.9(a).

Copy from re:SearchTX FAMILY JUDGES DOCKET Cause Number: 23DFAM337543 Type of Case: Divorce: Children Style of Case Attorneys

Petitioner’s Attorney: GARY CUNHA In the Matter of the Marriage of CARL LEE HILL and DOMINIQUE REED Respondent’s Attorney: DOMINIQUE AC REED

Orders of Court 09/15/2025 Docket Entry

Court reviewed Emergency Motion for Temp Ex parte Relief. Court denies motion.

Page 1 of 1 23DFAM337543 In the Matter of the Marriage of CARL LEE HILL and DOMINIQUE REED 09/15/2025 Copy from re:SearchTX Filed 10/24/2025 12:46 PM Joanna Staton, District Clerk District Court - Bell County, TX by Melissa Wallace , Deputy

NO. 23DFAM337543

CARL LEE HILL § DISTRICT COURT § PLAINTIFF § § v. § 146TH DISTRICT § § DOMINIQUE A REED § DEFENDANT § BELL COUNTY, TEXAS

EMERGENCY MOTION FOR PARTIAL DISTRIBUTION OF FUNDS FROM RECEIVERSHIP ESTATE.

TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, DOMINIQUE REED ("Movant"), acting Pro Se, and files this Emergency Motion for Partial Distribution of Funds from the Receivership Estate, and in support thereof, would respectfully show the Court as follows:

I. INTRODUCTION

1. Movant respectfully requests an emergency partial distribution of her equity funds currently held by the court-appointed Receiver. This is Movant’s second request for such relief. The Court considered and denied a prior motion on September 15, 2025, which was filed when an eviction was a pending threat. The circumstances have now critically escalated. Movant has exhausted all possible alternatives to secure the required cash bond. She lacks the personal

FWD CC SMW 10/24/25 assets or credit history required for traditional underwriting, and securing a surety bond is not feasible as it requires 100% cash collateral, which she does not possess. The potential harm that was previously a future risk has now ripened into a certain, imminent, and irreparable injury that will occur today, October 24, 2025, without the Court’s immediate intervention.

2. Specifically, the County Court has ordered that a supersedeas bond/Cash Deposit be paid by 4:45 p.m. today to stay a writ of possession that will render Movant and her 18-year-old daughter homeless. This motion is not a request to reconsider the prior ruling, but rather a necessary plea based on a material and adverse change in circumstances that now presents a clear case of irreparable harm. Movant has a vested interest in the funds held by the Receiver and has no other means to prevent the guaranteed loss of her family's housing, personal property, and transportation.

II. FACTUAL BACKGROUND

3. The court-appointed Receiver is in possession of proceeds from the sale of the marital residence. These funds include Movant’s substantial equity interest and represent Movant's sole financial resource after losing her job. Movant is recently unemployed and has no other income or assets.

4. Movant currently lacks the funds for basic necessities, including food and utilities, further compounding the emergency nature of this request.

5. Movant and her 18-year-old daughter, who is a named tenant on their apartment lease, face immediate removal from their home. Following an adverse ruling in an eviction appeal in the County Court at Law, Movant must deposit a cash deposit/check in lieu of a supersedeas bond of $5,382.00 into the court’s registry to prevent the issuance of a writ of possession.

6. The absolute deadline for this payment is 4:45 p.m. on October 24, 2025. Failure to pay the bond will result in the immediate issuance of the writ, leading to homelessness.

7. In addition to the bond, Movant is required to pay $897.00 into the court registry on or before November 1, 2025, as a condition of maintaining the appeal, continuing each month on the 1st until the appeal mandate.

8. All of Movant’s personal property is located in storage units. The storage facility has scheduled the contents for auction on November 6, 2025, due to non-payment. This property includes all of her family’s furniture, clothing, and irreplaceable personal effects.

9. The property where Movant resides will not make exceptions to the tow policy and has begun tagging Movant’s vehicles for towing due to expired registrations. The lack of a stable and legal vehicle recently caused Movant to lose her job. This situation is compounded by the fact that Movant’s ex-spouse, after numerous requests, has refused to provide his residential address, which is necessary to effectuate the title transfers of the vehicles awarded to Movant in the divorce. This non-compliance creates an additional barrier to legally owning and operating the vehicles, causing further undue hardship. One vehicle was already towed prematurely, before the date on the warning sticker, Movant was then required to arrange for its pickup, causing further hardship. Without funds to renew the registration and the ability to legally transfer title as ordered in the divorce, the loss of essential transportation is imminent.

III. ARGUMENT AND AUTHORITIES

For emergency relief to be granted, a movant must typically establish (1) a probable right to the relief sought; (2) a probable, imminent, and irreparable injury in the interim; and (3) no adequate remedy at law. See Butnaru v. Ford Motor Co., 84 S.W.3d 198, 204 (Tex. 2002). Movant meets this standard.

A. Movant Will Suffer Imminent and Irreparable Injury.

10. An injury is irreparable if the injured party cannot be adequately compensated in damages or if the damages cannot be measured by any certain pecuniary standard. Id. The harms facing Movant are the very definition of irreparable.

11. Certain Homelessness: If the cash payment in lieu of the supersedeas bond is not posted by 4:45 p.m. today, Movant and her daughter will be forcibly removed from their home.

Homelessness is a profound and irreparable harm that a later award of money cannot cure.

12. Long-Term Barrier to Housing: The issuance of a writ of possession will create a formal unlawful eviction judgment on the public records of both Movant and her 18-year-old daughter. For a young adult, this judgment creates a severe, multi-year impediment to securing future housing, a harm that transcends monetary value and prejudices her ability to achieve independence.

13. Permanent Loss of Personal Property: The scheduled storage auction on November 6, 2025, will result in the permanent loss of all the family's tangible property, including items of sentimental value that are, by their nature, irreplaceable.

14. Loss of Essential Transportation: The imminent towing of Movant’s vehicles will cut off her ability to seek employment, attend court proceedings, or manage essential family needs, creating a cycle of crisis for which monetary damages are an inadequate remedy.

B. Movant Has a Probable Right to the Relief Sought.

15. The funds held by the Receiver are, in significant part, Movant’s own property, representing her equity interest in the sold marital residence. While the final division of the receivership estate is pending, her right to a substantial portion of these specific funds is not in dispute.

This motion does not ask the Court to award property, but merely to release a small portion of Movant's own funds to prevent a manifest injustice. Denying access to these funds under these extreme circumstances is contrary to the equitable purpose of a receivership, which is to preserve the property and secure justice for the parties, not to be an instrument of irreparable harm.

IV. CONCLUSION

Without the Court's immediate intervention, a series of irreversible and catastrophic events will unfold, beginning this afternoon. The relief requested is not a final determination of rights but a necessary advance against Movant's own funds to preserve the status quo and prevent a grave and inequitable outcome.

V. PRAYER

WHEREFORE, PREMISES CONSIDERED, Movant DOMINIQUE REED respectfully prays that the Court:

1. Grant an expedited hearing on this Motion due to the extreme and time-sensitive nature of the matter; 2. Grant this Emergency Motion for Partial Distribution; 3. Sign an Order directing the Receiver, MARK MAHLER, to immediately distribute from the receivership estate in the following sums: 4. $5,382.00 to be paid as a cash deposit or by check in lieu of a supersedeas bond to the COUNTY COURT AT LAW 1 registry cause #25CCV01420 by 4:45pm today October 24, 2025; 5. $897.00 to be paid into the court registry cause #25CCV01420 for the November 1, 2025 rent deposit; 6. $694.00 to be paid to Dominique Reed to cure the default on Movant's storage units to stop auction proceedings.

7. $134.00 to be paid to Dominique Reed to renew vehicle registrations of 2012 Jeep Wrangler and 2015 Toyota Tundra.

8. $500.00 to be paid to Dominique Reed for essential living expenses, including food and utilities.

9. Grant such other and further relief to which Movant may be justly entitled.

Respectfully submitted,

________________________________________ Dominique Reed, Pro Se Appellant (Address Confidential – ACP Participant) Email: [email protected] Phone: 512-763-2003 CERTIFICATE OF SERVICE

I hereby certify that on October 24, 2025, a true and correct copy of the foregoing Emergency Motion was served in accordance with the Texas Rules of Civil Procedure on the court-appointed Receiver, MARK MAHLER, and counsel for Plaintiff , GARY CUNHA, via state e-file system

DOMINIQUE REED RightSpace Storage - 3076 - Belton 1709 Sparta Road Belton , TX 76513 (254)312-2293 Duffy, Keira 2705 Mystic Mountain Lane Belton, TX 76513 Unit Number: 145 Date: 10/02/2025

Notice of Lien Sale- Texas Dear Keira Duffy,

Notice is hereby given that your rent is now thirty (30) days or more delinquent. To date, you have failed to respond to our attempts to collect the balance owed. As provided in your rental agreement you have been denied access to your storage space. The contents of your leased space are subject to the facility's operator's lien.

Balance owed: As of the date of this notice, you owe RightSpace Storage - 3076 - Belton $311.00 Description of Personal Property Stored: Entire contents of unit consisting of, but not limited to: air conditioner, motorcycle helmets, tow hitch, shredder, sofa, luggage, mattress, box spring, folding table, baby items, boxes, totes, clothes, misc.

Unless full payment for all charges due are paid within fourteen (14) days, from the date of this notice, the items stored in the Unit will be advertised for sale and the stored property will be sold or otherwise disposed of at the following date, time and place: Auction date and time: 11/06/2025, 10:00 AM. Your personal property will be listed for public bidding on-line at www.storagetreasures.com beginning two weeks before the Auction Date and Time which is when the highest bidder will be determined and the sale concluded.

Auction address: RightSpace Storage - 3076 - Belton 1709 Sparta Road Belton, TX 76513 This is the Address where the sale will be concluded after all bids are received.

If no person purchases the personal property at the sale, the property may be sold at a private sale or destroyed.

In order to prevent this from happening, payment IN FULL on your account by Cashier's Check, Money Order or Credit Card must be received at RightSpace Storage - 3076 - Belton's address above before the sale date and time. Rent and other charges will continue to accrue until paid in full.

If you or your spouse is in military service, please contact us concerning your current military status immediately.

If you have any questions, you may contact the facility manager, as owner's agent, at the facility address and phone number referenced above.

An itemized list of the amounts owed follows:

Charge Date Description Amount Tax Discount Payments/Allowance Balance Rent Charged - 08/28/2025 to 08/28/2025 96.00 0.00 0.00 0.00 96.00 09/27/2025 Insurance - 08/28/2025 to 08/28/2025 12.00 0.00 0.00 0.00 12.00 09/27/2025 Late Fee: $20/20%- 5 Days - 09/03/2025 20.00 0.00 0.00 0.00 20.00 08/28/2025 to 09/27/2025 Rent Charged - 09/28/2025 to 09/28/2025 96.00 0.00 0.00 0.00 96.00 10/27/2025 Insurance - 09/28/2025 to 09/28/2025 12.00 0.00 0.00 0.00 12.00 10/27/2025 09/29/2025 Set Lien- Texas 75.00 0.00 0.00 0.00 75.00

Sincerely,

RightSpace Storage - 3076 - Belton RightSpace Storage - 3076 - Belton 1709 Sparta Road Belton , TX 76513 (254)312-2293 Duffy, Keira 2705 mystic mountain lane Belton, TX 76513 Unit Number: 160 Date: 10/02/2025

Notice of Lien Sale- Texas Dear Keira Duffy,

Balance owed: As of the date of this notice, you owe RightSpace Storage - 3076 - Belton $255.00 Description of Personal Property Stored: Entire contents of unit consisting of, but not limited to: boxes, totes, end table, clothes, TV, vanity mirror, decor, misc.

Auction address: RightSpace Storage - 3076 - Belton 1709 Sparta Road Belton, TX 76513 This is the Address where the sale will be concluded after all bids are received.

If no person purchases the personal property at the sale, the property may be sold at a private sale or destroyed.

If you or your spouse is in military service, please contact us concerning your current military status immediately.

If you have any questions, you may contact the facility manager, as owner's agent, at the facility address and phone number referenced above.

An itemized list of the amounts owed follows:

Charge Date Description Amount Tax Discount Payments/Allowance Balance Rent Charged - 08/07/2025 to 08/07/2025 58.00 0.00 0.00 0.00 58.00 09/06/2025 Insurance - 08/07/2025 to 08/07/2025 12.00 0.00 0.00 0.00 12.00 09/06/2025 Late Fee: $20/20%- 5 Days - 08/13/2025 20.00 0.00 0.00 0.00 20.00 08/07/2025 to 09/06/2025 Rent Charged - 09/07/2025 to 09/07/2025 58.00 0.00 0.00 0.00 58.00 10/06/2025 Insurance - 09/07/2025 to 09/07/2025 12.00 0.00 0.00 0.00 12.00 10/06/2025 09/10/2025 Set Lien- Texas 75.00 0.00 0.00 0.00 75.00 Late Fee: $20/20%- 5 Days - 09/13/2025 20.00 0.00 0.00 0.00 20.00 09/07/2025 to 10/06/2025

Sincerely,

RightSpace Storage - 3076 - Belton RightSpace Storage - 3076 - Belton 1709 Sparta Road Belton, TX 76513 (254)312-2293 Keira Duffy 2705 Mystic Mountain Lane Belton, TX 76513

MONTHLY INVOICE IMPORTANT INFORMATION Please pay on or before the Payment Due Date below. You can pay by (1) credit card, (2) check, (3) cashier's check, (4) money order or (5) sign into the NSA Storage Customer Portal at https://nsabrands-payment.ssm-erp.com/ Please note we no longer accept cash payments.

Questions about your Invoice? Please call your RightSpace Storage - 3076 - Belton Manager at (254)312-2293.

Invoice Number: 251021050356374 Unit # Charge Date Description Amount Tax Discount Total New Dues Rent Charged - 10/28/2025 to 145 10/28/2025 $96.00 $0.00 $0.00 $96.00 11/27/2025 145 10/28/2025 Insurance - 10/28/2025 to 11/27/2025 $12.00 $0.00 $0.00 $12.00

Other Dues Rent Charged - 08/28/2025 to 145 08/28/2025 $96.00 $0.00 $0.00 $96.00 09/27/2025 145 08/28/2025 Insurance - 08/28/2025 to 09/27/2025 $12.00 $0.00 $0.00 $12.00 Late Fee: $20/20%- 5 Days - 145 09/03/2025 $20.00 $0.00 $0.00 $20.00 08/28/2025 to 09/27/2025 Rent Charged - 09/28/2025 to 145 09/28/2025 $96.00 $0.00 $0.00 $96.00 10/27/2025 145 09/28/2025 Insurance - 09/28/2025 to 10/27/2025 $12.00 $0.00 $0.00 $12.00 145 09/29/2025 Set Lien- Texas $75.00 $0.00 $0.00 $75.00 Late Fee: $20/20%- 5 Days - 145 10/04/2025 $20.00 $0.00 $0.00 $20.00 09/28/2025 to 10/27/2025 Notice Date: 10/21/2025 Payment Due Date: Total Amount Due : 10/28/2025 Total Due $439.00 Prepaid Rent/Fee $0.00 Balance Due $439.00

Have you moved? Contact the office or sign into the NSA Storage Customer Portal at https://nsabrands-payment.ssm-erp.com/ Thank you for renting from RightSpace Storage - 3076 - Belton CAUSE NO. 25CCV01420 § IN THE COUNTY COURT § VS. § AT LAW #1 DEFENDANT § BELL COUNTY, TEXAS FINAL JUDGMENT On this day, came to be heard the above-entitled and numbered cause. Plaintiff, appeared by and through their attorney and announced "ready". Defendant, DOMINIQUE REED, DAKOTA HILL AND ALL OCCUPANTS, although duly noticed did not appear/appeared pro-se and announced "ready".

No jury having been demanded; the entire matter was submitted to the Court. After hearing and considering of the pleadings and evidence, the Court finds that DOMINIQUE REED, DAKOTA HILL ANDAL CUPANTS are justly indebted to for back rent in the amount of $ attorney fees, along with the court costs in the amount of $179.00, plus post-judgment interest at the rate df 7.50% per annum until judgment is paid in full.

The Court also finds is entitled to possession of the property located at:

IT IS THEREFORE ORDERED, ADJUDGED, AND DECREED that CYPRESS CREEK AT SOUTH CEDAR have and recover of and from said DOMIN QUE REED, DAKOTA HILL AND ALL OCCUPANTS the sum of $3,125. for back rent, $ attorney fees, along with court costs in the amount of $179.00, plus post judgment interest at the rate of 7.50% per annum until judgment is paid in full.

IT IS FURTHER ORDERED that the said have restitution of the said premises by midnight on October 24", 2025, for which let Writ of Possession issue, to wit: property located at:

A PARTY AFFECTED BY THIS ORDER HAS THE RIGHT TO APPEAL TO THE THIRD COURT OF APPEALS, AUSTIN, TEXAS.

If the appeal is taken, monthly rent to be paid into the Registry of the Court in the amount of $897.00 on the first day of the month. If the monthly rent is not paid, Writ of Possession may issue without further hearing.

Also, a Supersedeas Bond in the amount of $5,382.00 must be filed by 4:45 pm on October 24", 2025, in the County Clerk's office located at 1201 Huey Rd, Belton, TX 76513 to stay a pending judgm SIGNED THIS 14TH DAY OF OCTOBER, 2025.

FILED FOR RECORD Judgd Présiding

OCT 15 2° SHELLEY cer" COUNTY CLK. pe.

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: 107262183 Filing Code Description: Motion - No Fee Filing Description: EMERGENCY MOTION FOR PARTIAL DISTRIBUTION OF FUNDS FROM RECEIVERSHIP ESTATE PH SAW Status as of 10/27/2025 1:23 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Dominique Reed [email protected] 10/24/2025 12:46:03 PM SENT Service Only [email protected] 10/24/2025 12:46:03 PM SENT Gary Cunha [email protected] 10/24/2025 12:46:03 PM SENT Mark Mahler [email protected] 10/24/2025 12:46:03 PM SENT Shirley Smith [email protected] 10/24/2025 12:46:03 PM SENT Filing Submitted Envelope Number: 108138371 Case Number: 23DFAM337543 Case Style: In the Matter of the Marriage of CARL LEE HILL and DOMINIQUE REED

The filing below has been submitted to the clerk's office for review. Please allow 24 - 48 hours for clerk office processing.

Filing Details Court Bell County - District Clerk Date/Time Submitted 11/17/2025 3:58 PM CST Filing Type Motion - No Fee SUPPLEMENTAL EMERGENCY MOTION FOR PARTIAL Filing Description WITHDRAWAL OF FUNDS FROM COURT REGISTRY (SUPPLEMENTING MOTION FILED OCTOBER 24, 2025) Type of Filing EFileAndServe Filed By Dominique Reed Filing Attorney Fee Details Your account is never charged until your filing is accepted. If you see any pending charges on your account prior to acceptance, this is an authorization hold to ensure the funds are available so your filing can be accepted without delay.

If the filing is canceled or rejected these funds will be released and will return to your account according to your financial institution's policies (typically 3-10 business days).

This envelope is pending review and fees may change.

Case Fee Information $0.00 Motion - No Fee $0.00 Total:$0.00 (The envelope still has pending filings and the fees are subject to change) Document Details Lead Document FINAL.pdf Lead Document Page Count File Copy Download Document This link is active for 45 days.

For technical assistance, contact your service provider Need Help? Help Visit: https://efiletexas.gov/contacts.htm Email: [email protected] Please do not reply to this email. It was automatically generated.

Filed 11/19/2025 10:32 AM Joanna Staton, District Clerk District Court - Bell County, TX by MaryBeth DeLeon , Deputy

NO. 23DFAM337543

CARL LEE HILL § DISTRICT COURT § PLAINTIFF § § v. § 146TH DISTRICT § § DOMINIQUE A REED § DEFENDANT § BELL COUNTY, TEXAS

SUPPLEMENTAL EMERGENCY MOTION FOR PARTIAL WITHDRAWAL OF FUNDS FROM COURT REGISTRY (SUPPLEMENTING MOTION FILED OCTOBER 24, 2025)

TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW DOMINIQUE A. REED, Pro Se, and files this Supplemental Emergency Motion for Partial Withdrawal of Funds from the Court Registry, supplementing her original Emergency Motion filed October 24, 2025, which remains pending without hearing or ruling. Movant respectfully shows the Court as follows:

I. INTRODUCTION & PROCEDURAL HISTORY

1. Movant filed an Emergency Motion on October 24, 2025, requesting immediate release of a portion of the equity awarded to her in the Final Decree of Divorce signed May 28, 2024. These funds are currently held in the Bell County District Court Registry following the receiver’s sale of the marital residence on August 15, 2025. Upon deposit of the sale proceeds into the District Court Registry, the Receiver was formally discharged in this cause.

2. Movant has made repeated, documented attempts to obtain a hearing date or ruling, including FWD TO CC 11.20.25 MW emails to the Court Coordinator on October 24, October 28, and November 13, 2025, and calls to the District Clerk’s Office on November 3, 6, and 10, 2025. Despite these efforts, Movant has not been successful in securing a setting. As a self‑represented party, Movant faces added difficulty navigating procedure but has acted diligently to comply with the Court’s requirements.

3. The Bell County District Clerk confirmed that $8,410.00 is currently on deposit in the Court Registry and available for disbursement upon further orders of the court.

4. Movant files this Supplemental Emergency Motion due to the urgent risk of losing appellate jurisdiction, housing, and significant property.

II. FACTUAL BACKGROUND

1. The marital residence was sold under a court appointed Receiver. The Order Approving Sale signed August 15, 2025 required proceeds to be deposited into the District Court Registry.

2. Movant was awarded one half of the net equity. The amount requested of $8,410.00 has been verified as available by the District Court Clerk.

3. Funds are needed for: $5,382 supersedeas deposit; $1,794 rent registry payment for months November and December; $600 storage/truck; $134 registration for vehicles; $500 essentials food/utilities.

4. Movant relocated property under an amnesty agreement involving the storage account. Additional storage is required. “Movant has already incurred moving expenses, as shown by the U‑Haul receipt (Exhibit P). Despite renting one storage unit, the space was insufficient to hold all property. The requested withdrawal amount of $8,410.00 includes funds necessary to secure additional storage to prevent the loss of essential belongings awarded in the Divorce Decree.”

5. Movant has no savings, credit, or alternative funds.

III. APPELLATE JURISDICTION AT RISK (SEPARATE CIVIL CASE):

This Motion relates to a separate civil appeal pending in the Fifteenth Court of Appeals, where Movant and her daughter Dakota Hill are co-appellants in an eviction matter. A temporary stay was issued by the appeals court on October 29th, 2025, However on November 10, 2025, Appellee filed a Motion to Dissolve the Stay, claiming Movant failed to make required deposits and arguing that Movant does not have the funds to pay the supersedeas bond and court registry rent. This claim is directly contradicted by the verified availability of $8,410.00 in equity funds accessible to Movant from the balance currently held in the registry of this District Court under Cause No. 23DFAM337543.

Although the Plaintiff in the pending Court of Appeals matter disputes Movant’s position and alleges that she is stalling or lacks funds, the record demonstrates that Movant’s inability to make the required payments arises solely from her lack of access to the equity awarded in the Final Decree of Divorce dated May 28, 2025. Those funds remain in the District Court Registry following the receiver’s discharge, and cannot be withdrawn without an order of this Court. Movant has made diligent efforts to obtain release of the funds, including filing an Emergency Motion on September 15, 2025, which was denied. Movant is not refusing to pay; she is legally barred from doing so absent Court authorization. Without immediate relief, dissolution of the appellate stay will result in loss of possession of Movant’s home, rendering the appeal moot and causing irreparable harm. Once possession is lost and stability is destroyed, no monetary award or subsequent remedy can restore the home, cure the appeal, or undo the consequences of eviction and displacement. The harm is immediate, ongoing, and incapable of being adequately compensated after the fact.

IV. LEGAL STANDARD (THREE-PRONG TEST) Movant meets all elements: 1. Probable right: Funds awarded and available.

2. Irreparable harm: Loss of possession is irreparable harm.

3. No adequate remedy: Only this Court can release funds.

V. RESPONDENT’S MISREPRESENTATIONS & UNCLEAN HANDS (RESERVED):

Movant asserts that Respondent engaged in material misrepresentations and conduct amounting to unclean hands, which directly contributed to the wrongful diminution of Movant’s awarded equity.

These actions include the use of false statements, misleading exhibits, and strategic abuse of process designed to strip Movant of her rightful property division. While Movant reserves all rights to pursue sanctions, restitution, and other relief in a separate motion, she places the Court on notice that Respondent’s misconduct has already caused substantial harm to her equity interest and continues to prejudice her ability to secure stability.

VI. RESERVATION OF RIGHTS:

Movant’s acceptance of funds pursuant to this Motion shall not constitute a waiver of any right or claim regarding the receivership, sale, or distribution of property. Movant expressly preserves the right to:

1. Obtain a complete receivership accounting; 2. Challenge any fees, costs, or expenses previously disbursed; 3. Challenge compliance with the Final Decree of Divorce; 4. Challenge material misrepresentations made in connection with these proceedings; 5. Assert claims based on unclean hands or other equitable defenses; 6. Seek restitution, surcharge, disgorgement, or sanctions as appropriate; 7. File future motions addressing irregularities, inequities, or other improper conduct.

VII. PRAYER FOR RELIEF:

Movant respectfully prays that the Court:

1. Grant this Emergency Supplemental Motion in full instanter; because dissolution of the appellate stay will result in immediate loss of possession of Movant’s home, rendering the appeal moot and causing irreparable harm. Such harm cannot be cured by monetary damages or subsequent relief, and only immediate withdrawal of funds paid into the trial court registry will preserve Movant’s statutory right to appeal and prevent homelessness.

2. Order the immediate release of $8,410.00 from the District Court Registry to Movant for the express purpose of curing statutory deficiencies and preventing irreparable harm; 3. Enter findings supporting the necessity of emergency relief to preserve Movant’s rights and stability;

4. Acknowledge and incorporate the District Clerk’s verification of available funds into the Court’s Order;

5. Grant Movant leave to file a separate Motion for Surcharge, Restitution, and Sanctions against the Receiver for loss of equity resulting from the Receiver’s unauthorized sale of the marital residence in direct violation of the Final Decree of Divorce and Texas Family Code § 9.007; 6. Grant Movant leave to file a separate Motion for Sanctions, Restitution, and Relief against Respondent Carl Hill and third parties acting in concert with him based on their Fraud on the Court and the submission of false sworn affidavits on material facts in initiating the receivership, which caused undue hardship and diminution of Movant’s awarded equity;

7. Grant Movant such other and further relief, general and special, at law and in equity, to which she may be justly entitled.

Respectfully submitted, /s/ Dominique A. Reed Participant, Address Confidentiality Program Email: [email protected] Phone: 512-763-2003

CERTIFICATE OF SERVICE I hereby certify that on November 17, 2025, a true and correct copy of this SUPPLEMENTAL EMERGENCY MOTION FOR PARTIAL WITHDRAWAL OF FUNDS FROM COURT REGISTRY was served via the Texas e‑File system upon Gary Cunha, attorney of record for Respondent Carl Hill, in Cause No. 23DFAM337543.

Respectfully submitted, /s/ Dominique Reed, Pro Se EXHIBIT INDEX EXHIBIT LIST ● Exhibit A – Emergency Motion filed October 24, 2025 ● Exhibit B – Motion to Dissolve Stay (Appellee filing, November 10, 2025) ● Exhibit C – Final Judgment, Trial Court (October 15, 2025) ● Exhibit D – Divorce Decree (May 28, 2024) ● Exhibit E – Order Approving Sale and Discharging Receiver ● Exhibit F – Declaration of Clerk Balance Confirmation (November 12, 2025) ● Exhibit G – Amnesty Agreement and Declaration Regarding Storage Units ● Exhibit H – Photograph of Temporary Vehicle Tags (showing need for renewal) ● Exhibit I – Denial of Emergency Motion for Temporary Relief (September 15, 2025) ● Exhibit J – Email to Court Coordinator (October 24, 2025) ● Exhibit K – Follow‑up Email to Court Coordinator (October 28, 2025) ● Exhibit N – Follow‑up Email to Court Coordinator (November 13, 2025) ● Exhibit O – Declaration of Calls to District Clerk’s Office (November 3, 6, and 10, 2025) ● Exhibit P – U‑Haul Receipt and Declaration (November 2025) ● Exhibit Q – Rental Receipt for New Storage Unit and Declaration (November 2025) Filed 10/24/2025 12:46 PM Joanna Staton, District Clerk District Court - Bell County, TX EXHIBIT A by Melissa Wallace , Deputy

NO. 23DFAM337543

CARL LEE HILL § DISTRICT COURT § PLAINTIFF § § v. § 146TH DISTRICT § § DOMINIQUE A REED § DEFENDANT § BELL COUNTY, TEXAS

EMERGENCY MOTION FOR PARTIAL DISTRIBUTION OF FUNDS FROM RECEIVERSHIP ESTATE.

I. INTRODUCTION

FWD CC SMW 10/24/25 EXHIBIT A assets or credit history required for traditional underwriting, and securing a surety bond is not feasible as it requires 100% cash collateral, which she does not possess. The potential harm that was previously a future risk has now ripened into a certain, imminent, and irreparable injury that will occur today, October 24, 2025, without the Court’s immediate intervention.

II. FACTUAL BACKGROUND

4. Movant currently lacks the funds for basic necessities, including food and utilities, further compounding the emergency nature of this request.

EXHIBIT A 5. Movant and her 18-year-old daughter, who is a named tenant on their apartment lease, face immediate removal from their home. Following an adverse ruling in an eviction appeal in the County Court at Law, Movant must deposit a cash deposit/check in lieu of a supersedeas bond of $5,382.00 into the court’s registry to prevent the issuance of a writ of possession.

6. The absolute deadline for this payment is 4:45 p.m. on October 24, 2025. Failure to pay the bond will result in the immediate issuance of the writ, leading to homelessness.

9. The property where Movant resides will not make exceptions to the tow policy and has begun tagging Movant’s vehicles for towing due to expired registrations. The lack of a stable and legal vehicle recently caused Movant to lose her job. This situation is compounded by the fact that Movant’s ex-spouse, after numerous requests, has refused to provide his residential address, which is necessary to effectuate the title transfers of the vehicles awarded to Movant in the divorce. This non-compliance creates an additional barrier to legally owning and operating the vehicles, causing further undue hardship. One vehicle was already towed EXHIBIT A prematurely, before the date on the warning sticker, Movant was then required to arrange for its pickup, causing further hardship. Without funds to renew the registration and the ability to legally transfer title as ordered in the divorce, the loss of essential transportation is imminent.

III. ARGUMENT AND AUTHORITIES

A. Movant Will Suffer Imminent and Irreparable Injury.

11. Certain Homelessness: If the cash payment in lieu of the supersedeas bond is not posted by 4:45 p.m. today, Movant and her daughter will be forcibly removed from their home.

Homelessness is a profound and irreparable harm that a later award of money cannot cure.

12. Long-Term Barrier to Housing: The issuance of a writ of possession will create a formal unlawful eviction judgment on the public records of both Movant and her 18-year-old EXHIBIT A daughter. For a young adult, this judgment creates a severe, multi-year impediment to securing future housing, a harm that transcends monetary value and prejudices her ability to achieve independence.

B. Movant Has a Probable Right to the Relief Sought.

EXHIBIT A IV. CONCLUSION

V. PRAYER

WHEREFORE, PREMISES CONSIDERED, Movant DOMINIQUE REED respectfully prays that the Court:

1. Grant an expedited hearing on this Motion due to the extreme and time-sensitive nature of the matter; 2. Grant this Emergency Motion for Partial Distribution; 3. Sign an Order directing the Receiver, MARK MAHLER, to immediately distribute from the receivership estate in the following sums: 4. $5,382.00 to be paid as a cash deposit or by check in lieu of a supersedeas bond to the COUNTY COURT AT LAW 1 registry cause #25CCV01420 by 4:45pm today October 24, 2025; EXHIBIT A 5. $897.00 to be paid into the court registry cause #25CCV01420 for the November 1, 2025 rent deposit; 6. $694.00 to be paid to Dominique Reed to cure the default on Movant's storage units to stop auction proceedings.

7. $134.00 to be paid to Dominique Reed to renew vehicle registrations of 2012 Jeep Wrangler and 2015 Toyota Tundra.

8. $500.00 to be paid to Dominique Reed for essential living expenses, including food and utilities.

9. Grant such other and further relief to which Movant may be justly entitled.

Respectfully submitted,

________________________________________ Dominique Reed, Pro Se Appellant (Address Confidential – ACP Participant) Email: [email protected] Phone: 512-763-2003 EXHIBIT A

CERTIFICATE OF SERVICE

DOMINIQUE REED EXHIBIT A

RightSpace Storage - 3076 - Belton 1709 Sparta Road Belton , TX 76513 (254)312-2293 Duffy, Keira 2705 Mystic Mountain Lane Belton, TX 76513 Unit Number: 145 Date: 10/02/2025

Notice of Lien Sale- Texas Dear Keira Duffy,

Auction address: RightSpace Storage - 3076 - Belton 1709 Sparta Road Belton, TX 76513 This is the Address where the sale will be concluded after all bids are received.

If no person purchases the personal property at the sale, the property may be sold at a private sale or destroyed.

EXHIBIT A

If you or your spouse is in military service, please contact us concerning your current military status immediately.

If you have any questions, you may contact the facility manager, as owner's agent, at the facility address and phone number referenced above.

An itemized list of the amounts owed follows:

Sincerely,

RightSpace Storage - 3076 - Belton EXHIBIT A

RightSpace Storage - 3076 - Belton 1709 Sparta Road Belton , TX 76513 (254)312-2293 Duffy, Keira 2705 mystic mountain lane Belton, TX 76513 Unit Number: 160 Date: 10/02/2025

Notice of Lien Sale- Texas Dear Keira Duffy,

Auction address: RightSpace Storage - 3076 - Belton 1709 Sparta Road Belton, TX 76513 This is the Address where the sale will be concluded after all bids are received.

If no person purchases the personal property at the sale, the property may be sold at a private sale or destroyed.

EXHIBIT A

If you or your spouse is in military service, please contact us concerning your current military status immediately.

If you have any questions, you may contact the facility manager, as owner's agent, at the facility address and phone number referenced above.

An itemized list of the amounts owed follows:

Sincerely,

RightSpace Storage - 3076 - Belton EXHIBIT A

RightSpace Storage - 3076 - Belton 1709 Sparta Road Belton, TX 76513 (254)312-2293 Keira Duffy 2705 Mystic Mountain Lane Belton, TX 76513

Questions about your Invoice? Please call your RightSpace Storage - 3076 - Belton Manager at (254)312-2293.

Late Fee: $20/20%- 5 Days - 145 10/04/2025 $20.00 $0.00 $0.00 $20.00 09/28/2025 to 10/27/2025 Notice Date: 10/21/2025 Payment Due Date: Total Amount Due : 10/28/2025 Total Due $439.00 Prepaid Rent/Fee $0.00 Balance Due $439.00

Have you moved? Contact the office or sign into the NSA Storage Customer Portal at https://nsabrands-payment.ssm-erp.com/ Thank you for renting from RightSpace Storage - 3076 - Belton SUPPLMENTAL START EXHIBIT A CAUSE NO. 25CCV01420 § IN THE COUNTY COURT § VS. § AT LAW #1 DEFENDANT § BELL COUNTY, TEXAS FINAL JUDGMENT On this day, came to be heard the above-entitled and numbered cause. Plaintiff, appeared by and through their attorney and announced "ready". Defendant, DOMINIQUE REED, DAKOTA HILL AND ALL OCCUPANTS, although duly noticed did not appear/appeared pro-se and announced "ready".

The Court also finds is entitled to possession of the property located at:

IT IS FURTHER ORDERED that the said have restitution of the said premises by midnight on October 24", 2025, for which let Writ of Possession issue, to wit: property located at:

A PARTY AFFECTED BY THIS ORDER HAS THE RIGHT TO APPEAL TO THE THIRD COURT OF APPEALS, AUSTIN, TEXAS.

FILED FOR RECORD Judgd Présiding

OCT 15 2° SHELLEY cer" COUNTY CLK. pe.

ACCEPTED EXHIBIT B 15-25-00197-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 11/10/2025 12:20 PM NO. 15-25-00197-CV CHRISTOPHER A. PRINE CLERK In the Fifteenth Court of Appeals DOMINIQUE REED and DAKOTA HILL, Appellants v. CYPRESS CREEK AT SOUTH CEDAR, Appellee

On appeal from the County Civil Court at Law No. 1 of Bell County, Texas, Cause No. 25CCV01420 __________________________________________________________________ APPELLEE’S RESPONSE TO APPELLANTS’ EMERGENCY MOTION TO STAY JUDGMENT AND WRIT OF POSSESSION PENDING APPEAL OR, IN THE ALTERNATIVE, MOTION TO DISSOLVE TEMPORARY STAY __________________________________________________________________ TO THE HONORABLE JUSTICES OF THE FIFTEENTH COURT OF APPEALS: COMES NOW, Appellee, CYPRESS CREEK AT SOUTH CEDAR, and files its Response to Appellants’ Emergency Motion to Stay Judgment and Writ of Possession Pending Appeal or, in the Alternative, Motion to Dissolve Temporary Stay and, in support thereof, would show unto the Court the following.

INTRODUCTION This appeal stems from a final judgment in a forcible detainer action. (CR 81). In relevant part, the final judgment states: EXHIBIT B IT IS FURTHER ORDERED that the said CYPRESS CREEK AT SOUTH CEDAR have restitution of the said premises by midnight on October 24, 2025, for which let Writ of Possession issue, to wit: property located at: S Cedar Road, Apt #11208 Temple, Texas 76502.

A PARTY AFFECTED BY THIS ORDER HAS THE RIGHT TO APPEAL TO THE THIRD COURT OF APPEALS, AUSTIN, TEXAS.

Also, a Supersedeas Bond in the amount of $5,382.00 must be filed by 4:45 pm on October 24, 2025, in the County Clerk’s office located at 1201 Huey Rd, Belton, TX 76513 to stay a pending judgment.

(CR 81).

On October 20, 2025, Appellants filed their Notice of Appeal. (CR 97).

Appellants then filed their Emergency Motion to Stay Judgment and Writ of Possession Pending Appeal (hereinafter referred to as “Motion”) on October 29, 2025. The crux of Appellants’ Motion is that they do not currently have the financial means to file the supersedeas bond. 1 On the same day, the Third Court of Appeals granted the motion and “temporarily stay[ed] enforcement of the trial court’s Appellants further challenges the validity of the final judgment. However, this goes to the merits of Appellants’ appeal and has no bearing on her responsibility to file a supersedeas bond in order to pursue her appeal.

4905-1895-4104, v. 1 EXHIBIT B judgment and execution of the writ of possession pending further orders of this Court.” The Third Court of Appeals further requested Appellee to file a response to the Motion by November 10, 2025. 2 As explained below, the Texas Property Code mandates that a final judgment in a forcible detainer action cannot, under any circumstances, be stayed unless an appellant first complies with her supersedeas bond requirements. As Appellants have failed to do so, this Court should deny Appellants’ Motion and lift and/or dissolve the temporary stay issued by the Third Court of Appeals.

II.

ARGUMENT “A forcible detainer and detainer action is an eviction procedure to determine the right to immediate possession of real property.” In re Callier, No. 12-24-00076- CV, 2024 Tex. App. LEXIS 3361, *4 (Tex. App.—Tyler May 14, 2024, orig.

proceeding). It is a special proceeding intended to be a “speedy, simple, and inexpensive means to obtain immediate possession of property.” Marshall v. Housing Authority, 198 S.W.3d 782, 787 (Tex. 2006); see also In re Callier, 2024 Tex. App. LEXIS 3361 at *4. Once a judgment in a forcible detainer action is rendered, trial courts are given broad discretion in determining the amount and type of security required. See Nemeth v. Mindful Home Ventures, No. 03-25-00377-CV,

In the interim, this appeal was transferred to the Fifteenth Court of Appeals.

4905-1895-4104, v. 1 EXHIBIT B 2025 Tex. App. LEXIS 3906, *2 (Tex. App.—Austin June 5, 2025, no pet.) (citing Hernandez v. U.S. Bank Tr. N.A., 527 S.W.3d 307, 309 (Tex. App.—El Paso 2017, no pet.) (explaining that trial court “is given broad discretion in determining the amount and type of security required”); Stevenson v. Franklin Gardens Apartments, 511 S.W.3d 829, 832 (Tex. App.—El Paso 2016, no pet.) (stating that when setting amount of supersedeas bond, the trial court may take into consideration value of rents likely to accrue during appeal)).

More importantly, “[a] judgment of a county court may not under any circumstances be stayed pending appeal unless, within 10 days of the signing of the judgment, the appellant files a supersedeas bond in an amount set by the county court.” TEX. PROP. CODE § 24.007 (emphasis added). As this makes clear, an “appellate court’s power to stay the judgment of the county court in a forcible detainer action is limited; it is only empowered to stay the judgment of the county court in a forcible detainer action if a supersedeas bond has been filed.” See Nemeth, 2025 Tex. App. LEXIS 3906 at *2 (quoting Usatequi v. Meller, No. 04-05-00324- CV, 2006 Tex. App. LEXIS 582, 2006 WL 166436, at *1 (Tex. App.—San Antonio Jan. 25, 2006, no pet.) (mem. op.)); see also Coleman v. Pflugerville Wells Branch, LLC, No. 03-24-00765-CV, 2025 WL 352186, at *2 (Tex. App.—Austin Jan. 31, 2012, order). Finally, an appellant’s asserted indigence is not a basis for forgoing the requirement of a supersedeas bond. See Morse v. Fed. Nat’l Mortg. Ass’n, No. 4905-1895-4104, v. 1 EXHIBIT B 05-18-00999-CV, 2018 Tex. App. LEXIS 8115, 2018 WL 4784585, at *2 (Tex. App.—Dallas Oct. 4, 2018, no pet.) (mem. op.); In re Callier, 2024 Tex. App. LEXIS 3361 at *4 (“[i]ndigence does not relieve a party of the obligation to file a supersedeas bond”).

As Appellants have failed to comply with the supersedeas bond requirements, there is no legal basis for this Court to stay the county court’s judgment.

Accordingly, Appellants’ Motion should be denied, and the temporary stay should be lifted and/or dissolved. See Nemeth, 2025 Tex. App. LEXIS 3906 at *3 (“Given that Nemeth has not complied with the supersedeas requirements set out in the trial court’s final judgment, we dissolve our prior order granting temporary emergency relief and staying any writ of possession or garnishment.”); see also Cave v. Kensington Apts. Austin, LP, No. 03-24-00442-CV, 2024 Tex. App. LEXIS 6063, *2 (Tex. App.—Austin Aug. 21, 2024, no pet.) (“Even if it had not been rendered moot, we would lift the stay in light of the information provided by Kensington Apartments in its response about Cave’s failure to post the supersedeas bond … [and] [w]e deny Cave’s July 17, 2024 Emergency Motion to Stay or Recall Writ of Possession.”); Coleman v. Pflugerville Wells Branch, LLC, No. 03-24-00765-CV, 2025 WL 352186, at *2 (Tex. App.—Austin Jan. 31, 2012, order) (dissolving order granting temporary stay when supersedeas bond requirements were not met).

4905-1895-4104, v. 1 EXHIBIT B

III.

PRAYER Appellee, CYPRESS CREEK AT SOUTH CEDAR, respectfully prays that the Honorable Court deny Appellants’ Emergency Motion to Stay Judgment and Writ of Possession Pending Appeal, lift and/or dissolve the temporary stay issued by the Third Court of Appeals, and grant any other relief to which it is entitled.

Respectfully Submitted, HOOVER SLOVACEK LLP /s/ Joshua Anderson______________ Joshua Anderson State Bar No. 24027198 [email protected] Richard Alexander Barclay State Bar No. 24125110 [email protected] Galleria Tower II 5051 Westheimer, Suite 1200 Houston, Texas 77056 Telephone: (713) 977-8686 Facsimile: (713) 977-5395 ATTORNEYS FOR APPELLEE, CYPRESS CREEK AT SOUTH CEDAR

4905-1895-4104, v. 1 EXHIBIT B

CERTIFICATE OF SERVICE Pursuant to Texas Rule of Appellate Procedure 9.5, I hereby certify that on this the 10th of November 2025, a true and correct copy of the foregoing was served via electronic filing, to all counsel of record.

Dakota Hill P.O. Box 12108 MC068 Austin, Texas 78711 Dominique Reed P.O. Box 12108 MC068 Austin, Texas 78711

/s/ Joshua Anderson Joshua Anderson

4905-1895-4104, v. 1 EXHIBIT B Automated Certificate of eService This automated certificate of service was created by the efiling system.

Brooke Broderick on behalf of Joshua Anderson Bar No. 24027198 [email protected] Envelope ID: 107860988 Filing Code Description: Response Filing Description: Appellee Cypress Creek at South Cedar's Response to Emergency Motion to Stay Judgment and Writ of Possession Status as of 11/10/2025 12:22 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Brooke Broderick [email protected] 11/10/2025 12:20:41 PM SENT Alex Barclay [email protected] 11/10/2025 12:20:41 PM SENT Christy Case [email protected] 11/10/2025 12:20:41 PM SENT Dominique ACReed [email protected] 11/10/2025 12:20:41 PM SENT Joshua Anderson [email protected] 11/10/2025 12:20:41 PM ERROR EXHIBIT C CAUSE NO. 25CCV01420 § IN THE COUNTY COURT § VS. § AT LAW #1 DEFENDANT § BELL COUNTY, TEXAS FINAL JUDGMENT On this day, came to be heard the above-entitled and numbered cause. Plaintiff, appeared by and through their attorney and announced "ready". Defendant, DOMINIQUE REED, DAKOTA HILL AND ALL OCCUPANTS, although duly noticed did not appear/appeared pro-se and announced "ready".

The Court also finds is entitled to possession of the property located at:

IT IS FURTHER ORDERED that the said have restitution of the said premises by midnight on October 24", 2025, for which let Writ of Possession issue, to wit: property located at:

A PARTY AFFECTED BY THIS ORDER HAS THE RIGHT TO APPEAL TO THE THIRD COURT OF APPEALS, AUSTIN, TEXAS.

FILED FOR RECORD Judgd Présiding

OCT 15 2° SHELLEY cer" COUNTY CLK. pe.

EXHIBIT D R-3. All sums of cash in the possession of Respondent or subject to Respondent's sole control, including funds on deposit, together with accrued but unpaid interest, in banks, savings institutions, or other ﬁnancial institutions, which accounts stand in Respondent's sole name or from which Respondent has the sole right to withdraw funds or which are subject to Respondent's sole control.

R4. All individual retirement accounts, simpliﬁed employee pensions, annuities, and variable annuity life insurance beneﬁts in Respondent's name.

R-S. All sums, whether matured or unmatured, accrued or unaccrued, vested or otherwise, together with all increases thereof, the proceeds therefrom, and any other rights related to any proﬁt-sharing plan, retirement plan, Keogh plan, pension plan, employee stock option plan, 401(k) plan, employee savings plan, accrued unpaid bonuses, disability plan, or other beneﬁts existing by reason of Respondent's past, present, or future employment.

R-6. All nonretirement beneﬁts arising out of Respondent's membership in any union.

R7. All policies of life insurance (including cash values) insuring Respondent's life.

R-8. All brokerage accounts, stocks, bonds, mutual funds, and securities registered in Respondent's name, together with all dividends, splits, and other rights and privileges in connection with them.

R-9. One-half of the real property having physical address 2705 Mystic Mountain Ln, Belton, Bell County, Texas, to be sold in accordance with the provisions below.

R10. The 2016 Honda Civic Motor Vehicle, together with all prepaid insurance, keys, and title documents.

IT IS ORDERED AND DECREED that Petitioner, Carl Hill, shall timely pay, as a part of the division of the estate of the parties, and shall indemnify and hold Respondent, Dominique Reed, and Respondent's property harmless from any failure to so discharge, these items: P-l. All debts, charges, liabilities, and other obligations incurred by Petitioner from and after January 2023 unless express provision is made in this decree to the contrary.

P-2. The notes associated with any vehicles awarded to Petitioner in this ﬁnal decree of divorce.

IT IS ORDERED AND DECREED that Respondent, Dominique Reed, shall pay, as a part of the division of the estate of the parties, and shall indemnify and hold Petitioner, Carl Hill, and Petitioner's property harmless from any failure to so discharge, these items: R-l. All debts, charges, liabilities, and other obligations incurred by Respondent from and after January 2023 unless express provision is made in this decree to the contrary.

R-2. The notes associated with any vehicles awarded to Respondent in this ﬁnal decree of divorce.

Hill Final Decree EXHIBIT D

IT IS ORDERED that the panics shall execute any documents necessary to effectuate the division of property within 3 days of receipt of said documents, this includes any powers of attorney. IT IS FURTHER ORDERED that the parties shall cooperate with transferring title to the motor vehicles awarded herein.

IT IS ORDERED AND DECREED that each party shall send to the other party by email to the other party's last known email address, within three days of its receipt, a copy of any correspondence from a creditor or taxing authority concerning any potential liability of the other party.

Sale 0f Home IT IS FURTHER ORDERED AND DECREED that the property and all improvements located thereon at HIGHLAND ESTATES PHASE ONE REPLAT NO 2 (L3 B1), BLOCK 001, LOT 003A, ACRES 0.73 according to the map, plat, or deed records of Bell County, Texas, and more commonly known as 2705 Mystic Mountain Ln, Belton, Bell County, Texas, shall be sold under the following terms and conditions: l. The parties shall list the property with a duly licensed real estate broker having sales experience in the area where the property is located. IT IS ORDERED that the parties shall comply with the recommendations of the realtor including making any necessary repairs within a timely manner upon receiving notice from the realtor of the necessity of the repairs.

3. The property shall be sold for a price that is mutually agreeable to Petitioner and Respondent. If Petitioner and Respondent are unable to agree on a sales price or if either party fails to cooperate with the sale of the property, on the application of either party, the property shall be sold under terms and conditions determined by a court-appointed receiver and sold to the ﬁrst bona ﬁde purchaser paying at least the appraised value. Petitioner shall pay ﬁfty percent and Respondent shall pay ﬁfty percent of the cost of the appraisal when due to complete this sale. If either party fails to pay their half of the appraisal, the other party shall be reimbursed for this amount from the proceeds from the sale of the home. The Court shall Order the party at fault for the necessity of appointing a receiver to pay all fees associated with the appointment of the receiver, including attomey's fees and court costs. This money shall be taken from the proceeds of the sale of the home.

4. Petitioner shall continue to make all payments of principal, interest, taxes, and insurance on the property during the pendency of the sale, and Respondent shall have the exclusive right to enjoy the use and possession of the premises until six months after December 6, 2023. IT IS ORDERED that Respondent shall move out of the home on or before six months after December 6, 2023. All reasonable repairs necessary to keep the property in its present condition shall be paid by Petitioner.

5. The net sales proceeds (deﬁned as the gross sales price less cost of sale and full payment of any mortgage indebtedness or liens on the property) shall be distributed as follows:

Hill Final Decree EXHIBIT D 1. Carl Hill shall be reimbursed for one-half of each month the mortgage is paid after December 6, 2023.

2. Carl Hill shall be reimbursed for any reasonable repairs made to the home prior to the sale of the home.

3. Any reimbursement, if necessary, in accordance with an appraisal or costs associated with the appointment of a receiver in accordance with any further Order of this Court, as necessary.

4. The remaining proceeds shall be split equally between the parties.

Income Taxes

1T lS ORDERED AND DECREED that Dominique Reed and Carl Hill shall be equally responsible for all federal income tax liabilities of the parties allocable to the period from the date of marriage through December 31, 2023, and each party shall timely pay 50 percent of any taxes, penalties, and interest due thereon and shall indemnify and hold the other party and the other party's property harmless from the portion of such tax, penalty, and interest required to be paid by the indemnifying party unless that additional tax, penalty, or interest resulted from a party's omission of income or claim of erroneous deduction, in which case that party shall pay, and hold the other party and the other party's property harmless from, the additional tax, penalty, and interest allocable to the omitted income or erroneous deduction.

IT IS ORDERED AND DECREED that if a refund of tax or other amounts is made for any year during the parties' marriage through December 31, 2023, each party shall be entitled to one-half of the refund amount, and the party receiving the refund check is designated a constructive trustee for the beneﬁt of the other party to the extent of one-half of the refund amount, and the party receiving the refund check shall pay to the other party one-half of the refund amount within ﬁve days of receipt of the refund check. Each party is ORDERED to endorse the refund check on presentation by the other party.

The term "I.R.C." means the Internal Revenue Code of 1986, as amended.

IT IS ORDERED AND DECREED that, for the calendar year 2023, each party shall ﬁle a federal income tax return and report thereon the reporting party's share of the income, gains, losses, deductions, and credits, including estimated taxes and withholding taxes, of the parties during the calendar year 2023 prior to the date of divorce, and of the reporting party on and after the date of divorce, in accordance with the I.R.C. and this decree.

IT IS ORDERED AND DECREED that each party shall use as a credit against that party's income tax liability for 2023 100 percent of all estimated tax payments and withholding taxes made by, in the name of, or for the beneﬁt of that party, 50 percent of the prior year tax overpayment carryforward of the parties to the calendar year 2023, and 50 percent of all estimated tax payments made in the names of both parties for the period prior to the date of divorce.

Hill Final Decree EXHIBIT E

No. 23DFAM337543 IN RE MARRIAGE OF § IN THE DIS RTCKRCOGRT § CARL LEE HILL § § OF BELL COUNTY, TEXAS and § § DOMINIQUE AC REED § 146th JUDICIAL DISTRICT

ORDER APPROVING SALE On this date the court examined the Report of Sale filed by MARK MAHLER, Receiver, of the following real property: Lot 3A, Block One, Highland Estates Phase One, Replat No. 2, an addition to the City of Belton, Bell County, Texas, according to the plat recorded as Instrument No. 2020012684, Official Public Records of Bell County, Texas.

The court finds that the property was sold to Justin Morgan and Kelsey Morgan, for a contract price of $430,000.00 under the terms and conditions set forth in the residential earnest money contract, a copy of which was attached to the Report of Sale. The court finds that the sale was properly made in conformity with law for a fair price and is satisfactory and in conformity with the order of this court appointing the Receiver dated November 4, 2024.

The court further finds that due notice of the filing of the Report of Sale of the hearing for its approval was duly given to all parties to this cause and that there was no objection to the terms described in the Report of Sale.

It is therefore ORDERED that the Report of Sale and the contract for sale of the above- described real property are approved and confirmed.

It is FURTHER ORDERED that proper conveyance of the real property described above be made by the Receiver to Justin Morgan and Kelsey Morgan, purchasers, upon compliance by the purchasers with the terms of sale as set forth in the Report of Sale.

146" District Cour!

EXHIBIT E It is FURTHER ORDERED that MARK MAHLER is awarded $ 25, BOO. as a fee for services rendered in this sale. The fee will be taxed and collected as costs of this suit to be paid be split h from the proceeds of sale at closing of the sale Fee to mallet Grove ond Realters + It is FURTHER ORDERED that 1 MARK MAHLER is authorized to pay reasonable and necessary attorney fees not to exceed $750.00 for assistance in preparation, filing, and approval of the Report of Sale and companion order, to be taxed and collected as costs of this suit to be paid from the proceeds of sale at closing of the sale.

It is FURTHER ORDERED that MARK MAHLER collect and deposit with the Clerk of this Court the proceeds from the sale of the real property described above, after deductions at closing for the fees and expenses stated above and in the Report of Sale, for distribution pursuant to further Order of this Court. Upon such deposit, MARK MAHLER shall be discharged as receiver in this cause.

SIGNED ¥ /5

PRESIDING JUDGE EXHIBIT F

EXHIBIT F-Declaration of Clerks Balance Confirmation

I, Dominique A. Reed, declare under penalty of perjury:

On November 12, 2025, I called the Bell County District Clerk’s Office regarding Cause No. 23DFAM337543. The clerk confirmed to me again by phone that the balance in the Court Registry was an amount sufficient to cover my emergency withdrawal request of $8,410.00.

Executed on this 17 day of November, 2025, in Bell County, Texas.

_____________________________ Dominique A. Reed, Pro Se EXHIBIT G Exhibit G – Declaration (Amnesty Agreement)

I, Dominique A. Reed, declare under penalty of perjury: 1. On November 6, 2025, I entered into an Amnesty Agreement with Right Space Storage regarding two storage units at risk of auction.

2. The units were set up under my daughter’s name, but I was solely responsible for paying balances and the property inside was mine.

3. I coordinated all arrangements with my daughter’s knowledge and approval.

4. The Agreement required me to vacate both units and remove all property by November 13, 2025.

5. Immediate funds are necessary to comply with this deadline and prevent loss of my property.

Executed on this 17 day of November, 2025, in Bell County, Texas.

_____________________________ Dominique A. Reed, Pro Se EXHIBIT H

Exhibit H– Temporary Registration Photos EXHIBIT I FAMILY JUDGES DOCKET Cause Number: 23DFAM337543 Type of Case: Divorce: Children Style of Case Attorneys

Petitioner’s Attorney: GARY CUNHA In the Matter of the Marriage of CARL LEE HILL and DOMINIQUE REED Respondent’s Attorney: DOMINIQUE AC REED

Orders of Court 09/15/2025 Docket Entry

Court reviewed Emergency Motion for Temp Ex parte Relief. Court denies motion.

Page 1 of 1 23DFAM337543 In the Matter of the Marriage of CARL LEE HILL and DOMINIQUE REED 09/15/2025 Copy from re:SearchTX EXHIBIT J

Mrs. Hernandez,

I am writing to notify the Court that I ﬁled an EMERGENCY MOTION FOR PARTIAL DISTRIBUTION OF FUNDS FROM RECEIVERSHIP ESTATE today in NO. 23DFAM337543 Due to the urgent circumstances described in the motion including imminent loss of housing stability and pending storage-unit auctions I respectfully request that the Court set this motion for the earliest possible hearing or advise if the Court is willing to consider it on an expedited submission basis.

This motion requests a limited, temporary release of funds from the receivership estate to prevent irreparable harm while the Receiver’s accounting and ﬁnal distribution remain pending. I am available at any date and time convenient to the Court, and I will coordinate promptly with all parties once a date is provided.

If the Court requires a separate motion for an emergency or expedited setting, please let me know and I will ﬁle it immediately.

Filed Motion Details: • Title: Emergency Motion for Partial Distribution of Funds from Receivership Estate • Filing Date: 10/24/2025 • Envelope ID: # 107262183 Thank you for your assistance. Your prompt attention to this request is greatly appreciated due to the emergency nature of the relief sought.

Respectfully, Dominique Reed Address Conﬁdentiality Program – Address Withheld Phone: 512-763-2003 Email: [email protected] EXHIBIT K

Dear Mrs. Hernandez, I am following up regarding the Emergency Motion for Partial Distribution of Funds from Receivership Estate in NO. 23DFAM337543, originally submitted via e-File on October 24, 2025 (Envelope ID: #107262183). I have since learned that the motion was not accepted by E-ﬁle until 10/27/2025 1:24 PM CST after the relevant deadline.

Despite this delay, I respectfully request that the Court consider setting the motion for hearing or ruling on submission, given the emergency nature of the relief sought and the continuing risk of irreparable harm. As outlined in the motion, I am facing imminent loss of housing and potential auction of essential property from storage units.

Additionally, I remain under time-sensitive appellate constraints. I intend to proceed with my appeal in the Third Court of Appeals, and a cash deposit is still required to avoid issuance of a writ. The motion’s resolution directly impacts my ability to comply with appellate requirements and preserve my rights.

Thank you again for your attention to this matter. I appreciate the Court’s consideration and remain hopeful for a timely resolution.

Respectfully, Dominique Reed Address Conﬁdentiality Program – Address Withheld Phone: 512-763-2003 Email: [email protected] EXHIBIT N

Dear Mrs. Hernandez, I am a self-represented party in Cause No. 23DFAM337543, pending in the 146th District Court.

I plan to ﬁle a Emergency Supplemental Motion today in response to the original motion ﬁled on October 24, 2025, as circumstances have changed since that submission.

Could you please advise me on the correct procedure to have this Emergency Supplemental Motion set for hearing or submission before the Court? I want to ensure I follow the proper steps, as I have not been successful in securing a setting through prior emails and calls to the Court.

Thank you very much for your guidance and assistance.

Respectfully, Dominique Reed Email: [email protected] 512-763-2003 EXHIBIT O Exhibit O – Declaration of Calls to District Clerk’s Office

I, Dominique A. Reed, declare under penalty of perjury: I made calls to the Bell County District Clerk’s Office on November 3, November 6, and November 10, 2025, to request a hearing date for my emergency motion. Despite these efforts and further guidance I was unable to get the motion set for hearing or ruling.

Executed on this 17 day of November, 2025, in Bell County, Texas.

_____________________________ Dominique A. Reed, Pro Se EXHIBIT P Order/Reservation Truck Reservation # 98236782 Pick Up Drop Off

Pick Up Time: Drop Off Time: Thursday, 11/13/2025 By: Friday, 11/14/2025 11:30 AM 12:15 AM

Pick Up Location: Drop Off Location U-Haul Moving & Storage of Midway Same as pick up location Address: 3914 S General Bruce Dr Temple, TX 76502 (Next to Geeks phone repair, Past McDonalds off I35) Phone Numbers: (254) 727-7216 (tel:2547277216) (877) 251-5354 (tel:8772515354)

Order Details Order Status: Overdue

Item Qty Total

15' Truck 1 $29.95 hours of use requested, subject to availability.

You are currently >nancially responsible for any damage to your equipment.

None $0.00 The estimated value of your rental truck is $50,000 USD.

Estimated Miles - $1.09/mile 2 $2.18 Environmental Fee 1 $1.00

Subtotal: $33.13 EXHIBIT P

Exhibit P – Declaration (U‑Haul Receipt)

I, Dominique A. Reed, declare under penalty of perjury: 1. On November 13, 2025, I rented a U‑Haul truck to move property from storage units pursuant to the Amnesty Agreement deadline of November 13, 2025. Attached is the U‑Haul receipt.

2. Despite renting one additional storage unit, the space was insufficient to hold all property.

Immediate funds are required to secure additional storage.

3. These expenses are already included in the total withdrawal request of $8,410.00.

Executed on this 17 day of November, 2025, in Bell County, Texas.

_____________________________ Dominique A. Reed, Pro Se EXHIBIT Q Temple Star Storage 1733 Airport Trail Temple, TX 76504 254-230-3363 RENTAL AGREEMENT LICENSE: TSSA51388_51386 1. TENANT INFORMATION ALTERNATE ACCESS Tenant Name: Dominique Reed Tenant authorizes Lessor, at Lessor’s option, to provide Tenant’s space Street Address 1: number(s), access code, account status, or assistance with lock removal to City/State/Zip: persons listed below.

Employer's Name: Dakota Hill #to00 Social Security Number: EMERGENCY CONTACT INFORMATION Driver's License/State: / List name, address, and phone of person(s) who may be contacted in an Telephone (Home): (512) 763-2003 emergency. (Do not list an individual living with you.)Unless tenant states Telephone (cell): (512) 763-2003 otherwise in paragraph6, Lessor may at Lessor’s option allow such person(s) Work Phone: or Tenant’s brother, sister, spouse, parent, child over 18 or estate executor to E-Mail: [email protected] have access to Tenant’s space if such person signs an affidavit that Tenant is deceased, incarcerated, permanently missing or permanently incapacitated.

The above address or Tenant’s email address provided will be used for all written Lessor may discuss Tenant’s account with any such persons at any time. notices to Tenant unless Tenant gives written notice of change to Lessor.

Contact Name: Street Address: City/State/Zip: Phone: 2. TENANT INFORMATION Are you or your spouse in the Military/Reserves at the time of signing Tenant agrees to immediately notify Lessor of changes in Tenant’s mailing address, email, phone number, or other information Yes this Agreement? #rbp00:Yes:No| No provided by Tenant. Except as provided in paragraph 33, a change of Military Branch: #to01 mailing or email address will not be effective unless the new address is COMPLETE and the notice is mailed, faxed, or emailed to Lessor’s [ check one or both if applicable] address stated herein in WRITING and SIGNED and DATED by Tenant #cb00 in the reserves, National Guard, or Texas State Guard and actually RECEIVED by Lessor. See also paragraph 33. #cb01 on active duty.

3. TENANTS SPACE.

Space Number: G107 Approx. Size (exact dimensions may vary): 10.0 x 10.0 Access Code: 6218 Minimum Lease Term: 1 month 4. DOLLARS AND DATES. Tenant's security deposit is $ 0.00. Tenant's right to occupy the space begins on November 13, 2025, and continues on a month to month basis, subject to paragraph 9. (a) Rent ......... Monthly ............. $ 87.30 (j) Charge for overlocking Tenant's space or (b) Monthly Rental Due Day 1 chaining/booting property when authorized by paragraphs 24(2) or 32(f) $ 0.00 (c) Initial late charge if not received by day 5 (k) Charge for sending statutory notice of claim for after due date. $ 15.00 unpaid sums $ 0.00 (d) Subsequent late charge if rent not received by (l) Charge for newspaper ad of sale, per ad (to cover day 15 after due date $ 20.00 time, inconvenience, and ad costs) $ 0.00 (e) Returned payment charge (including bank (m) Charge for conducting foreclosure sale at public charges, mail costs, time and overhead) $ 50.00 auction for nonpayment $ 125.00 (f) Charge for returned mail (not providing address change) $ 0.00 (g) Charge for locking space when unlocked or (n) Charge for having to judicially evict Tenant (to cover improperly locked. $ 20.00 time and inconvenience, but does not include (h) Charge per day if Tenant fails to lock after 7- attorneys' fees or court costs) $ 0.00 day notice $ 0.00 (i) Charge for removing Tenant's lock when (o) Charge per hour for removing or cleaning when authorized by paragraphs 18, 19, 24 and 32. $ 20.00 Tenant litters or fails to clean, remove items, or vacate --- paragraphs 10, 37, and 38(c) $ 15.00 5. PAYMENTS AND NOTICES.

Payment Type Accepted Not Accepted Payments may be by money order, or certified cashier’s check. However, Lessor may change permitted Cash mode of payment at any time, upon notice to Tenant. If cash is accepted by Lessor, it is Tenant’s ✓ responsibility to obtain and keep a receipt from management for each cash payment. All payments must be delivered or mailed to Lessor’s mailing address in the signature block below. Notices to Lessor must be Personal/Company Check ✓ hand delivered, mailed, faxed, texted or emailed. When giving notice to Lessor, Tenant has the burden of proving delivery to Lessor. EXCEPT AS OTHERWISE PROVIDED BY LAW, NOTICE MAY BE Credit Card ✓ PROVIDED TO TENANT VIA EMAIL OR TEXT IF TENANT ELECTS TO PROVIDE AN EMAIL ADDRESS OR CELL PHONE NUMBER. (6) Tenant must be current in all obligations at time of move-out. (c) Tenant will be liable for damages and for cleaning charges under paragraph 4(o) and all disposal costs for Tenant’s failure to remove all contents and debris, stains or fluid/leakage, or failure to “broom clean” the space (if it has a solid floor), and other lease violations.

EXHIBIT Q TENANT LESSOR Dominique Reed X #sg1 Stephiane Burnette X #sg2 Signature of Tenant or Tenant's authorized agent (and title if any) Facility name and address are shown below. Facility name is actually or assumed name of Lessor. Mailing address for all payments and notices to Date: November 13, 2025 Lessor is the facility address unless a different mailing address is shown below.

Lessor's phone number and fax number (if any) and email address (if any) Dominique Reed are also shown below.

Printed name of individual signing Driver's license of individual signing: State : Email address: [email protected] Temple Star Storage 1733 Airport Trail Temple, TX76504 Other ID if no driver's license #to02 Phone: 254-230-3363 Fax: .

20116168 Texas Vehicle License: state and number: #to03 Email Address: [email protected] Texas Property Code Chapter 59 governs the Self-Storage Lien process.

A copy of the statute can be found at capitol.texas.gov A copy may also be accessed from the Texas Self Storage Association website: www.txssa.org Self-Service Storage Rental Agreement, Official TSSA Form #1-21 (Rev 09/21) Copyright 2021, Texas Self Storage Association, Inc. EXHIBIT Q Exhibit Q – Declaration Regarding Rental Receipt for New Storage Unit

I, Dominique A. Reed, declare under penalty of perjury:

1. On November 13, 2025, I rented a new storage unit to comply with the Amnesty Agreement deadline of November 13, 2025. Attached is the rental receipt.

2. Despite securing this unit, the space was insufficient to hold all property. Immediate funds are required to secure an additional storage unit to prevent loss of household furniture and essential belongings.

3. These expenses are already included in the total withdrawal request of $8,410.00.

Executed on this 17 day of November, 2025, in Bell County, Texas.

_____________________________ Dominique A. Reed, Pro Se Automated Certificate of eService This automated certificate of service was created by the efiling system.

Envelope ID: 108270444 Filing Code Description: Motion - No Fee Filing Description: SUPPLEMENTAL EMERGENCY MOTION FOR PARTIAL WITHDRAWAL OF FUNDS FROM COURT REGISTRY (SUPPLEMENTING MOTION FILED OCTOBER 24, 2025) -PH SAW Status as of 11/21/2025 8:54 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Dominique Reed [email protected] 11/20/2025 9:43:22 AM SENT Service Only [email protected] 11/20/2025 9:43:22 AM SENT Karen ARagsdale [email protected] 11/20/2025 9:43:22 AM SENT Teresa Schiller [email protected] 11/20/2025 9:43:22 AM SENT Filed 11/19/2025 10:34 AM Joanna Staton, District Clerk District Court - Bell County, TX by MaryBeth DeLeon , Deputy

NO. 23DFAM337543

CARL LEE HILL § DISTRICT COURT § PLAINTIFF § v. § 146TH DISTRICT § § DOMINIQUE A REED § DEFENDANT § BELL COUNTY, TEXAS

NOTICE OF ADVERSE APPELLATE RULING AND RENEWED REQUEST FOR EMERGENCY ORDER INSTANTER

TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW DOMINIQUE A. REED, Movant, and files this Notice to inform the Court that the irreparable harm described in her Supplemental Emergency Motion (filed 11/17/2025) and Original Motion Emergency Motion Filed October 24, 2025 has now occurred.

1. On November 19, 2025, the Fifteenth Court of Appeals in Cause No. 15-25-00197-CV issued an Order DENYING temporary relief and LIFTING the Temporary Stay (See Attached Exhibit A: CoA Order).

2. The appellate court's action was necessitated by Movant's inability to file the required Supersedeas Bond and Court Registry Rent payments, which are verified to be available from the $10,493.33 balance in this District Court’s Registry .

3. Movant is now subject to the immediate execution of a Writ of Possession, which will render her and her co-appellant daughter homeless.

4. Movant RENEWS her request for the Court to sign the Order for Partial Withdrawal of Funds INSTANTER to allow her to cure the deficiency with the County Clerk before the Writ is executed.

PRAYER Movant respectfully prays that the Court consider this Notice and sign the Order for Withdrawal of Funds INSTANTER to prevent the immediate, irreparable loss of Appellants' property and right to appeal.

FWD CC 11.20.25 Respectfully Submitted, /s/ Dominique A. Reed [email protected] 512-763-2003

CERTIFICATE OF SERVICE I hereby certify that on November 19, 2025, a true and correct copy of this SUPPLEMENTAL EMERGENCY MOTION FOR PARTIAL WITHDRAWAL OF FUNDS FROM COURT REGISTRY was served via the Texas e‑File system upon Gary Cunha, attorney of record for Respondent Carl Hill, in Cause No. 23DFAM337543.

Respectfully submitted, /s/ Dominique Reed, Pro Se EXHIBIT A Order Filed November 19, 2025

In The Fifteenth Court of Appeals NO. 15-25-00197-CV DOMINIQUE REED AND DAKOTA HILL, Appellant V. CYPRESS CREEK AT SOUTH CEDAR, Appellee On Appeal from the County Court at Law No 1 Bell County, Texas Trial Court Cause No. 25CCV01420 ORDER Appellants Dominique Reed and Dakota Hill filed an Emergency Motion to Stay Judgment and Writ of Possession Pending Appeal with the Third Court of Appeals on October 29, 2025, seeking temporary injunctive relief under Texas Rules of Appellate Procedure 24.1(a), 24.4(a), and 29.3. The Third Court issued an order temporarily staying enforcement of the trial court’s judgment and execution of the writ of possession pending further orders. The Third Court also requested appellee Cypress Creek at South Cedar (“Cypress Creek”) file a response to the motion no later than November 10, 2025. The case was subsequently transferred to this Court on November 6, 2025. Cypress Creek filed its response on November 10, 2025.

The Court, having reviewed the motion, hereby DENIES Dominique Reed and Dakota Hill’s request for temporary relief. We further ORDER the temporary stay issued by the Third Court of Appeals lifted.

PER CURIAM Panel consists of Chief Justice Brister and Justices Field and Farris.

EXHIBIT B

Notification of Service Case Number: 23DFAM337543 Case Style: In the Matter of the Marriage of CARL LEE HILL and DOMINIQUE REED Envelope Number: 108138371 This is a notification of service for the filing listed. Please click the link below to retrieve the submitted document. If the link does not work, please copy the link and paste into your browser.

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Filing Details Case Number 23DFAM337543 In the Matter of the Marriage of CARL LEE HILL and DOMINIQUE Case Style REED Date/Time Submitted 11/17/2025 3:58 PM CST Filing Type Motion - No Fee SUPPLEMENTAL EMERGENCY MOTION FOR PARTIAL Filing Description WITHDRAWAL OF FUNDS FROM COURT REGISTRY (SUPPLEMENTING MOTION FILED OCTOBER 24, 2025) Filed By Dominique Reed Other Service Contacts not associated with a party on the case: Dominique Reed ([email protected]) Service Contacts Service Only ([email protected]) Gary Cunha ([email protected]) Shirley Smith ([email protected]) Document Details Served Document Download Document This link is active for 45 days. To access this document, you will be required to enter your email address. Click here for more information.

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Envelope ID: 108220368 Filing Code Description: Motion - No Fee Filing Description: NOTICE OF ADVERSE APPELLATE RULING AND RENEWED REQUEST FOR EMERGENCY ORDER INSTANTER BY DOMINIQUE A REED -PRO SE -PH SAW Status as of 11/21/2025 8:52 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Dominique Reed [email protected] 11/19/2025 10:34:10 AM SENT Service Only [email protected] 11/19/2025 10:34:10 AM SENT Gary Cunha [email protected] 11/19/2025 10:34:10 AM SENT Shirley Smith [email protected] 11/19/2025 10:34:10 AM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system.

Envelope ID: 108337613 Filing Code Description: Motion for Emergency Relief - Exempt Filing Description: EMERGENCY NOTICE OF EXECUTION OF WRIT OF POSSESSION AND EXTREME URGENCY 24HRS Status as of 11/21/2025 1:01 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Brooke Broderick [email protected] 11/21/2025 12:49:55 PM SENT Alex Barclay [email protected] 11/21/2025 12:49:55 PM SENT Dominique ACReed [email protected] 11/21/2025 12:49:55 PM SENT Joshua Anderson [email protected] 11/21/2025 12:49:55 PM ERROR

Case-law data current through December 31, 2025. Source: CourtListener bulk data.

Opinion

TO THE HONORABLE JUSTICES OF THE FIFTEENTH COURT OF APPEALS:

Dakota Hill, Pro EXHIBIT (A) COVER SHEET

THIS WRIT MAY BE EXECUTED AT ANY TIME ON OR AFTER THE SPECIFIED DATE.

​ ​ ​ ​ ​ ​ ​ ​ EXHIBIT (C) COVER SHEET

I. INTRODUCTION

NO. 23DFAM337543

EMERGENCY MOTION FOR PARTIAL DISTRIBUTION OF FUNDS FROM RECEIVERSHIP ESTATE.

I. INTRODUCTION

II. FACTUAL BACKGROUND

III. ARGUMENT AND AUTHORITIES

IV. CONCLUSION

V. PRAYER

OCT 15 2° SHELLEY cer" COUNTY CLK. pe.

NO. 23DFAM337543

I. INTRODUCTION & PROCEDURAL HISTORY

II. FACTUAL BACKGROUND

III. APPELLATE JURISDICTION AT RISK (SEPARATE CIVIL CASE):

V. RESPONDENT’S MISREPRESENTATIONS & UNCLEAN HANDS (RESERVED):

VI. RESERVATION OF RIGHTS:

VII. PRAYER FOR RELIEF:

NO. 23DFAM337543

EMERGENCY MOTION FOR PARTIAL DISTRIBUTION OF FUNDS FROM RECEIVERSHIP ESTATE.

I. INTRODUCTION

II. FACTUAL BACKGROUND

III. ARGUMENT AND AUTHORITIES

EXHIBIT A IV. CONCLUSION

V. PRAYER

CERTIFICATE OF SERVICE

DOMINIQUE REED EXHIBIT A

EXHIBIT A

EXHIBIT A

OCT 15 2° SHELLEY cer" COUNTY CLK. pe.

4905-1895-4104, v. 1 EXHIBIT B

III.

4905-1895-4104, v. 1 EXHIBIT B

OCT 15 2° SHELLEY cer" COUNTY CLK. pe.

SIGNED ¥ /5

PRESIDING JUDGE EXHIBIT F

3. TENANTS SPACE.

NO. 23DFAM337543

EXHIBIT B

EXHIBIT (C) COVER SHEET