NO.01-15-00112-CV 


In the First Court of Appeals 


Houston, Texas 


IN RE: MOTHER DOE AND FATHER DOE, INDIVIDUALLY AND AS 


NEXT FRIENDS OF JOHN DOE AND JANE DOE 


Original Proceeding from Cause No. 1045092 in 


County Court at Law No. Two (2), Harris County, Texas, 


Honorable Theresa Chang, Presiding Judge 


RELATORS' MOTION FOR REHEARING AND, 


IN THE ALTERNATIVE, 


MOTION FOR EN BANC CONSIDERATION 


The Cweren Law Firm 

Brian P. Cweren 

State Bar No. 24001956 

3311 Richmond Avenue, Suite 305 

Houston, Texas 77098 

(713) 622-2111 telephone 

(713) 622-2119 facsimile 

bcweren@cwerenlaw.com 

Counsel for Mother Doe and Father Doe, Individually and as Next Friends of 


John Doe and Jane Doe, 


Relators 


ORAL ARGUMENT REQUESTED 


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ACCEPTED

01-15-00112-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

5/1/2015 1:58:05 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 5/1/2015 1:58:05 PM CHRISTOPHER A. PRINE Clerk
Relators Mother and Father Doe, Individually and as 

and Jane this motion rehearing In to the 

OpInIOn the Court on April 1 2015. 

I. 	 COURT OF ERRED IN DENYING THE PETITION 

FOR WRIT OF MANDAMUS, THE PROTECTIVE 

ORDER AT ISSUE VIOLATES THE REQUIREMENTS OF RULE 194 

OF THE TEXAS OF CIVIL PROCEDURE. 

Rule 194 of the Rules of Civil governs 

Rule 194.3 that a responding must timely serve a written 

to a request for and that the requesting party is entitled 

a copy of any' or insuring agreements would provide 

for a judgment rendered in case. See Tex. R. 194 and 192.3. 

an Insunng usually at trial, the 

authority when allowed the Real in Interest to 

applicable insurance policies as "Confidential" or "Confidential-for Attorneys 

Only." This provision Protective Order is contrary to 

and, as a would effect on 

lawsuits in County, Texas. the Court of Appeals' 

Memorandum Opinion should on this issue. 

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This appeal was bya panel included 

Chief Justice and Justices and Lloyd. Court has the authority 

to grant the portion of this motion and submit the mandamus to 

the full court, en bane. case such an 

that resolution by the Court of en bane, is in that the protective 

Order at issue, as interpreted by Respondent, is so broad in its protection 

Defendants below, it will prevent a just adjudication underlying 

For these Relators request this Honorable Court 

Appeal to reconsider denial of Relators' Petitioner Writ Mandamus, 

in part. 

In the alternative, Relators request . Honorable Court consider the 

for Writ of Mandamus en bane. 

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CERTIFICATE OF COMPLIANCE 


I hereby certify that this document (upon exclusion of those contents 

exempted by Rule 9.4(i)(1) of the Texas Rules ofAppellate Procedure) contains 370 

words. 

{}-A --­ Brian P. Cweren 

CERTIFICATION 

I certify that I have reviewed the petition for writ of mandamus and have 

concluded that every factual statement made in the petition is supported by 

competent evidence included in the appendix or the record. 

Brian P Cweren 

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CERTIFICATE OF SERVICE 


As required by Texas Rule of Appellate Procedure 6.3 and 9.5(b), (d), ( e), I 

certify that I have served this document on all other parties -which are listed belowon the \ <OV day of May, 2015 as follows: 

Barbara L. Hachenburg 


Germer PLLC 


Three Allen Center 


333 Clay Street, Suite 4950 


Houston, Texas 77002 


By (check all that apply) 

personal delivery 

mail 

commercial delivery service 

X 	 fax (713) 739-7420 

Hon. Theresa Chang 


County Civil Court at Law Number Two (2) 


201 Caroline Street, Suite 740 


Houston, Texas 77002 


By (check all that apply) 


personal delivery 


X 	 mail 

commercial delivery service 

fax 

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