NO. 14-15-00788-CV 

IN THE COURT OF APPEALS 

FOURTEENTH JUDICIAL DISTRICT 

HOUSTON, TEXAS 

Bowen, Miclette & Britt Insurance Agency, LLC, 

Appellant, 

v. 

Christopher Taylor, 

Appellee.

On appeal from the 295th Judicial District Court of Harris County, Texas 

The Honorable Caroline Baker, Presiding 

Cause No. 2015-03943 

APPELLANT’S UNOPPOSED MOTION TO ABATE 

APPEAL PENDING FINALIZED SETTLEMENT

TO THE HONORABLE FOURTEENTH COURT OF APPEALS: 

 Appellant Bowen, Miclette & Britt Insurance Agency, LLC (“BMB”) files 

this Unopposed Motion to Abate Appeal Pending Finalized Settlement and 

requests the Court abate this appeal to allow time for the parties to finalize the 

settlement reached by the parties. BMB respectfully shows the Court as follows: 

1. On August 17, 2015, BMB filed a notice of appeal of the trial court’s 

order denying BMB’s request for a temporary injunction. Since BMB filed its 

ACCEPTED

14-15-00788-CV

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

10/1/2015 6:03:56 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 10/1/2015 6:03:56 PM CHRISTOPHER A. PRINE Clerk
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notice of appeal, the parties have reached an informal settlement which would 

dispose of this appeal. The parties are currently finalizing the settlement and it is 

anticipated the settlement will be finalized within the next thirty (30) days.

2. The Court has ordered the clerk’s record for this appeal be filed by 

October 14, 2015 and the reporter’s record be filed by October 11, 2015. The 

Court has also ordered BMB to file BMB’s docketing statement by October 1, 

2015. 

3. In order to preserve this Court’s resources and avoid unnecessary 

expense by the parties, BMB requests the Court abate this appeal so the parties 

may finalize their settlement agreement. Once the settlement agreement is 

finalized, BMB will seek dismissal of this appeal. In the unlikely event the parties 

cannot finalize the settlement agreement, BMB will notify the Court. 

4. BMB has conferred with Appellee’s counsel, Mr. Craig Dillard, 

regarding the relief requested herein. Appellee is unopposed to an abatement of 

the instant appeal pending the parties’ finalization of their settlement agreement. 

PRAYER 

For the above reasons, BMB respectfully requests the Court grant this 

motion and abate the present appeal pending finalization of the settlement 

agreement between the parties. 

 
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Respectfully submitted, 

 CHAMBERLAIN, HRDLICKA, WHITE,

 WILLIAMS & AUGHTRY

By: /s/ C. Larry Carbo, III 

William S. Helfand 

State Bar No. 09388250 

bill.helfand@chamberlainlaw.com 

 C. Larry Carbo, III 

 State Bar No. 24031916 

larry.carbo@chamberlainlaw.com 

Julie R. Offerman 

State Bar No. 24070360 

julie.offerman@chamberlainlaw.com 

1200 Smith Street, Suite 1400 

Houston, Texas 77002 

Telephone (713) 658-1818 

Telecopy (713) 658-2553 

ATTORNEYS FOR APPELLANT

 
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CERTIFICATE OF CONFERENCE 

 I hereby certify that the undersigned counsel for Appellant conferred by 

email with Appellee’s counsel on September 30, 2015. Appellee does not oppose 

abatement of this appeal. 

/s/ C. Larry Carbo, III 

 

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing motion has been 

served upon the following counsel of record via hand delivery, electronic 

submission, facsimile, and/or U.S. Mail on this the October 1, 2015, to the 

following: 

Rachel Powitzky Steely 

Megan Jennings Batchelor 

Craig Dillard 

GARDERE WYNNE SEWELL, LLP 

1000 Louisiana, Suite 3400 

Houston, Texas 77002 

Fax: 713-276-5555 

Email: rsteely@gardere.com 

Email: mbatchelor@gardere.com 

Email: cdillard@gardere.com 

 /s/ C. Larry Carbo, III