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CAUSE NO. 2012-33464-A 2/25/2015 11:17:52 AM Chris Daniel - District Clerk Harris County Envelope No. 4275629 By: Phyllis Washington Filed: 2/25/2015 11:17:52 AM



### LETICIA B. LOYA § IN THE DISTRICT COURT OF § 

### Plaintiff, § § 

### VS. § HARRIS COUNTY, TEXAS 

# HARRYL. TINDALL, § (^ 

# INDIVIDUALLY, § J^ AND TINDALL & ENGLAND 8 %£? 

### Defendants. § 190th JUDICIAL DISTRICT
r> 

### NOTICE OFAPPEA# 

### 7^ 

### NOTICE IS HEREBY GIVEN that LetiCuTB. Loya, Plaintiffin the above- 

## *S> named case, hereby appeals to the First<4?r the Fourteenth Houston Court of 

## c> *A* 

# Appeals from the district court's orde^-granting the Amended Motions to Dismiss

«% 

## Based on Mandatoiy Forum Sejecjon Clauses ofVilol, Inc., Michael Metz, and Antonio Maarraoui signed December 9, 2014; as well as the district court's order 

## granting Miguel Loya^^flbtion to Dismissed Based on a Mandator)' Forum Selection Clause signed January 15, 2015.' 5P



### The District Court signed the Order of Severance rendering these final and appealable orders on January 26, 2015 and an Amended Severance Order clarifying the docket number.Respectfully submitted, 

### PROVOST * UMPHREYLAWFIRM, L.L.P. 490 Park Street 

## P.O. Box4905 ^ 

## Beaumont, Texas 77704 ^(<|p (409) 835-6000 

### (409) 813-8605 (FAX) j^



## Bv: /s/JenniferJob^ JenniferJob ^F 

## State BarN^24050682 

## James E^yne 

# StateB^No. 00788171 ATTORNEYFORPLAINTIFF 

## CERTIFjAtEOF SERVICE I HEREBY CERTIFYM-hat a true and correct copy of the foregoing 

## instrument has been farni^lpl to all known counsel ofrecord via EFILE and/or 

## certifiedmail, returnrece^requestedonthis 25th dayofFebruary, 2015.

<U /s/ Jennifer Job ^ Jennifer Job 

## ^

# Oh I *t'K>\ \ < \( t*. 

# r&Aancc Ordc r 

# PROVOSlSbrUMPHREY

LAW FIRM L.L.P.
JENNIFERJOB ATTORNEY B0AR3 CERTIFIED: PERSONAL INJURY TRIAL LAW TEXAS BOARD OF LEGAL SPECIALIZATION fflMWItgffil ACCEPTED 01-14-01014-CV FIRST COURT OF APPEAl J HOUSTON. TEXAS 2/25/2015 11:59:17 AM

CHRISTOPHER PRIlill CLERK

February 25,2015
DESIGNATION OF RECORD ON APPEAL Civil/Family Post Trial Department 201 Caroline, Suite 250 Houston, Texas 77210 

## RE: Case#2012-33464 -^J) Styled: Leu'cia B. Loya v. Ian Taylor, Jacobus Sterken, Stichting Tinsel Group, Vitol Holding IIS.A., and Tinsel Group S.A.
Dear Sir or Madam: Plaintifffiled a notice of appeal in this case on February 25, 2015. In accordance with Appellate Rule 34.5(a) and (b), Plaintiffs request the clerk to prepare a clerk's record ofthe proceedings in this case for inclusion in the appellate record. Plaintiff requests the following items be included in the clerk's record. This list includes those items required by Appellate Rule 34.5(a); 1. The Court's docket sheet; 2. Plaintiffs' Original Petition, filed June 7, 2012; 3. Plaintiffs First Amended Petition and Jury Demand, filed June 6, 2014; 4. Defendant Miguel A. Loya's Original Answer, filed July 7, 2014;
5. Defendant Michael Metz & Antonio Maarraoui \s Joint Motion to Dismiss Based on a Mandatory Forum Selection Clause, Plea to the Jurisdiction, Plea in Abatement. Special Exceptions, and Subject Thereto, General Denial and Affirmative Defenses to Plaintiffs First Amended Petition, filed July 26, 2014; 6. Defendant Miguel A. Loya's Motion to Dismiss for Lack ofJurisdiction, Motion to Dismiss Based on a Mandatory Forum Selection Clause, and Motion to Stay and Application for Order Compelling Arbitration, filed August 18, 2014;

',90 PARKSTREET • EO. DOX-1905 • BEAUMONT, TEXAS7770-1 109-83S f>000 • 1000-289-0101 • PAX-109 038 8888 JJobQpulf.coin • wvQKpnvosunnpbnucoom Beaumont, TX • Houston, TX • NashvUIe.TN • North Utile Rode. AR7. Defendant Ian Taylor's Special Appearance, Motion to Dismiss Based on Mandatory Forum Selection Clause, Plea to Jurisdiction, Plea in Abatement, Special Exceptions and Subject Thereto General Denial and Affirmative Defenses to Plaintiffs First Amended Petition, filed 7/26/14; 8. Defendant Vitol Defendants' Amended Motion to Dismiss Based on Mandatory Forum SelectionClauses,filedOctober 27,2014; 9. PlaintiffLeticia B. Loya's Response to Vitol Defendants' Amended Motion to Dismiss Based onMandatory Forum Selection Clauses, filed November 3,2014; 

### 10. Plaintiff Leticia B. Loya's Response to Miguel Loya's Motion to Dismiss for LackofJurisdiction, Motion to Dismiss Based on a Mandatory Forum Selection 

### Clause, and Motion to Stay and Application for Order Compelling Arbitration, filed November 3,2014; 11. Thetrial court'sLetterto theParties, filed December 2,2014; 12. Order signed granting Vitol, Inc., Michael Metz, and Antonio Maarraoui's Amended Motion to Dismiss Based onMandatory Forum Selection Clauses, filed December 9,2014; 

### 13. Miguel A. Loya's Reply to Leticia Loya's Response toMiguel A. Loya's Motion to Dismiss Based on a Mandatory Forum Selection Clause, field January 13, 2015; 

### 14. Order signed Denying Miguel Loya's Motion to Stay and Application for Order Compelling Arbitration, filed January 15,2015; 

### 15. Order signed Denying Miguel Loya's Motion toDismiss for Lack ofJurisdiction, filed January 15,2015; 

### 16. Order signed Granting Miguel Loya's Motion to Dismiss Based on aMandatory Forum Selection Clause, filed January 15,2015; 

### 17. PlaintiffLeticia B. Loya's Sur-Reply toMiguel Loya's Motion to Dismiss Based on aMandatory Forum Selection Clause, filed January 20,2015; 18. OrderofSeverance, FiledJanuary 26,2015; 19. Amended Order ofSeverance, filed February 19, 2015; 20. Thenotice ofappeal filed February 25,2015; 21. A copyof thisrequest, filed thisdate.22. A certified bill of costs, including the cost for preparing the clerk's record, showingany creditsfor payments made. Should you require any assistance in locating any ofthese items, please contact the undersigned attorney. Sincerely,

JJ:gm