Appellate Docket Number o.5-19-o.o.689-CV

Appellate Case Style DOUGLAS DOYLE, ASHLEY DOYLE, MADISON DOYLE AND JOE PUTNAM.

VS ROBIN CHRISTOPHER

Companion Case No.:

Amended/corrected statement DOCKETING STATEMENT (Civil)

Appellate Court:

(to be tiled in the court of appeals upon perfection of appeal under TRAP 32)

I. Appellant

~ Person 0 Organization (choose one)

First Name: DOUGLAS

Middle Name:

Last Name:

Suffix:

Pro Se:

Address I:

Address 2:

City:

State: Texas

Telephone:

Fax:

Zip+4

ext.

)Organization (choose one)

Organization Name:

First Name: ROB.IN c~"·

Middle Name:

Last Name: CHRISTOPHER

Suffix:

Pro Se:

Address I:

Address j.

City:

State: Texas Zip+4:

Telephone ext.

Fax·

Emall

n. Appellant .-\ttoflley(s)

KJ Lead Attorney

First Name: JOE

Middle Name:

Last Name: PUTNAM

Suffix:

Law Firm Name:

Address 1:1425· W. Pioneer, Ste. 114

Address 2:

City:

State: Texas·: Zip+4: 750.61

Telephone: 972 259-2626

Fax: 972 254-1540.

;::,nail: j oeputnam@earth1ink. net

1641700.0.

ext.

First Name:

Middle Name:

Last Name: TORABI

Suffix:

Law Firm Name:

Address l: 1044,0., N. Central Expy., Ste 8

Address 2:

City:

State: Texas

Telephone: 972 200-7899

Fax. 972 767-5017

Zip+4: 75231

ext.

.v.;

Email:

SBN:240376o.5

Page 1 of7

ACCEPTED

05-19-00689-CV

FIFTH COURT OF APPEALS

DALLAS, TEXAS

6/19/2019 12:03 PM

LISA MATZ

CLERK

05-19-00689-CV

 FILED IN 5th COURT OF APPEALS DALLAS, TEXAS 6/19/2019 12:03:57 PM LISA MATZ Clerk
Appellate Docket Number

Appellate Case Style

Vs

Companion Case No.:

Amended/corrected statement DOCKETING STATEMENT (Civil)

Appel [ate Court:

(to be filed in the court of appeals upon perfection of appeal under TRAP 32)

I. Appellant n.

IKI Person 0 Organization (choose one)

First Name: MADTSClN

Middle Name:

Last Name:

Suffix:

Pro Se:

Address I:

Address 2:

City:

State: Texas Zip+4

Telephone:

Fax:

ext.

jOrganization (choose one)

Organization Name:

First Name:

Middle Name:

Last Name:

Suffix:

Pro Se:

Address 1:

Address I'

City:

State: Texas Zip+4:

Telephone ext.

Fax:

Emai]

o Lead Attorney

First Name:

Middle Name:

Last Name:

Suffix:

Law Firm Name:

Address I:

Address 2:

City:

State:

Telephone:

Fax:

email:

Lead Attorney

First Name:

Middle Name:

Last Name:

Suffix:

Law Firm Name:

Address 1:

Address 2:

City:

State: Texas

Telephone:

Fax:

Email:

SBN:

Zip+4:

ext.

Zip+4:

ext.

Page 1 of 7
Appellate Docket Number.

Appellate Case Style

Vs

Companion Case No.:

Amended/corrected statement. DOCKETING STATEMENT (Civil)

Appellate Court:

(to be tiled in the court of appeals upon perfection of appeal under TRAP 32)

L Appellant II. Appellant Attdrlley(s)

rn Person 0 Organization (choose one)

First Name: ASHLEY

Middle Name:

Last Name:

Suffix:

Pro Se:

Address I:

Address 2:

City:

State: Texas Zip+4

Telephone:

Fax:

ext.

Email:

o Lead Attorney

First Name:

Middle Name:

Last Name:

Suffix:

Law Firm Name:

Address I:

Address 2:

City:

State: Texas

Telephone:

Fax:

ext.

email:

III. ,Appe

o Person [Organization (choose one)

First Name:

Middle Name:

Last Name:

Suffix:

Pro Se:

Address 1:

Address 1:

City:

State Texas Zip+4:

'Telephone, ext

Fax

Emai}

Lead Attorney

First Name:

Middle Name:

Last Name:

Suffix:

Law Firm Name:

Address 1:

Address 2:

City:

State: Texas Zip+4:

Telephone:

Fax.

ext.

Email:

Page 1 of 7

SBN
Appellate Docket Number

Appellate Case Style

Vs

Companion Case No.:

Amended/corrected statement: DOCKETING STATEMENT (Civil)

Appellate Court:

(to be tiled in the court at appeals upon perfection of appeal under TRAP 32)

I. Appellant n. Appellant A-.(tOrlley(s)

~ Person 0 Organization (choose one)

First Name: JOE

Middle Name:

Last Name:

Suffix:

Pro Se:

Address I:

Address 2:

City:

State: Texas Zip+4

Telephone:

Fax:

ext.

Email:

First Name:

Middle Name:

Last Name:

Suffix:

Pro Se:

Address 1:

Address J'

City:

State Texas Zip+4:

lelephone ext.

Fax

IEmall.

o Lead Attorney

First Name:

Middle Name:

Last Name:

Suffix:

Law Firm Name:

Address 1:

Address 2:

City:

State: Texas

Telephone:

Fax:

ext.

email:

Lead Attorney

First Name:

Middle Name:

Last Name:

Suffix:

Law Firm Name:

Address I:

Address 2:

City:

State' Texas

I

::~ePhone:

Email

_SBN

Zip+4:

ext.

Page 1 of 7
Date order or judgment signed:

Date notice of appeal filed in trial court: Jt:l_;ne 1]; ~ 2.019

If mailed to the trial court clerk, also give the date mailed:

Interlocutory appeal of appealable order: 0 Yes Kl No

If yes, please specify statutory or other basis on which interlocutory order is appealable (See TRAP 28):

Type of judgment:

Accelerated appeal (See TRAP 28):

If

DYes IXJ No

Parental Termination or Child Protection? (See TRAP 28.4): DYes ~No

Permissive? (See TRAP 28.3): DYes IilNo

If yes, please specify statutory or other basis for such status:

Agreed? (See TRAP 28.2): DYes KJ No

Appeal should receive precedence, preference, or priority under statute or rule:

If yes, please

DYes '[] No

Does this case involve an amount under $100,000? IX] Yes ONo

Judgment or order disposes of all parties and issues: U Yes DNa

Apper 1 from final judgment: ~ Yes 0 No

Does the appeal involve the constitutionality or the validitv of a statute, rule, or ordinance? [J Yes £JNo

Motion to Modify Judgment: DYes IRI No If yes, date filed:

Request for Findings of Fact IKlYes DNa If yes, date filed: May 1

and Conclusions of Law:

Motion to Reinstate:

DYes IKINo If yes, date filed:

Malian under TRCP 306a:

DYes [Xl No If yes, date filed:

Other: DYes DNa

Affidavit filed in trial court:

Contest filed in trial court: DYes iii No If yes, date filed:

Date ruling on contest due:

Ruling on contest: 0Sustained o Overruled Date of ruling:

Page 2 of 7
IVIII. Bankruptcy

Has any party to the court's judgment filed for protection in bankruptcy which might affect this appeal?

If yes, please attach a copy of the petition.

DYes D No

Date bankruptcy filed: Bankruptcy Case Number:

Court:

Trial Court Clerk: 0 District 2(] County

Was clerk's record requested? XJ Yes D No

If yes, date requested: June 11, 2019

IX. Trial

County:

Trial Court Docket Number (Cause No.):

Trial Judge (who tried or disposed of case):

First Name: BRENDA

Middle Name:

Last Name:

If no, date it will be requested:

Were payment arrangements made with clerk?

UYes ONo Dlndigent

(Note: No request required under TRAP 34.S(a),(b»

Suffix:

Address 1:120)1"Ettit<St., Ste 2400:...A

Address 2 :

City: Dallas

State Texas 75270

Telephone:

Fax:

Email:

Reporter's or Recorder's Record:

Is there a reporter's record?

Was reporter's record requested?

~Yes D No

fXJYt;S ONo

Was there a reporter's record electronically recorded? 0Yes 0 No

If yes, date requested:

If no, date it will be requested:

Were payment arrangements made with the court reporter/court recorder? UYes 0 No Dlndigent

Page 3 of 7
fiJ Court Reporter

o Official

o Court Recorder

o Substitute

First Name:

Middle Name:

Last Name: GALINDO

Suffix:

Address I: 1201.:m:trn se :, Ste. 2400-A

Address 2:

City

State: Zip + 4:

Telephone:

Fax'

Email: j ackiegalindo@dallascounty. org

ext

X. Supersedeas BO'rid

Supersedeas bond filed: 0Yes 0 No If yes, date filed:

Will fiJr:: ~ Yes 0 No

XI. Extraordinary R~Her

Will you request extraordinary relief'{e.g. temporary or ancillary relief) from this Court? 0 Yes Kl No

If yes, briefly state the basis for your request:

~ir, ·4Jternijtl~~~~.'" ,"

Or 14th Court9cA-p. h

Should this appeal be referred to mediation?

Gth, 8th, 9th, lOth, 11th, nth, 13(h

DYes I]g No

If no, please

Has the case been through an ADR procedure? DYes [Xl No

If yes, who was the mediator?

What type of ADR procedure?

At what stage did the case go through ADR? D Pre-Trial D Post-Trial D Other

If other, please specify:

Type of case?

Give a brief description of the issue to be raised on appeal, the relief sought, and the applicable standard for review, if known (without

prejudice to the right to raise additional issues or request additional relief):

I How was the case disposed of?

I Summary of reliefgranted, including amount of money judgment, and if any, damages awarded,

Ilf money Judgment, what was the amount? Actual damages:

I Punitive (or similar) damages:

Page 4 of 7
fAttorney'S fees (trial) $6,148.50

Attorney's fees (appellate):

Other

If other. please specify:

Will you challenge this Court's jurisdiction? DYes [iJ No

Does judgment have language that one or more parties "take nothing"? 0 Yes fJ No

Does judgment have a Mother Hubbard clause? DYes IRl No

Other basis for finality? Disposition of issue in cont r over-sy

Rate the complexity of the case (use I for least and 5 for most complex): DID 2 KJ3 0 4 0 5

Please make my answer to the preceding questions known to other parties in this case.

Can the parties agree on an appellate mediator? 0 Yes 0 No

If yes, please give name, address, telephone, fax and email address:

Name Address Telephone

DYes 0 No

Fax Email

Languages other than English in which the mediator should be proficient:

Name of person filing out mediation section of docketing statement:

XIII. Related Matters

List any pending or past related appeals before this or any other Texas appellate court by court, docket number, and style.

Docket Number: Trial Court:

Style:

Vs.

Page 5 of7
IXIV,--p~~B~-noProgram: (Complete section if filing inthe 1st, 3rd,Sth, or 14th Courts of App-eals)

e Courts of Appeals listed above, in conjunction with the State Bar of Texas Appellate Section Pro Bono Committee and local Bar

sociations are conducting. a program to place a limited number of civil appeals with appellate counsel who will represent the appe llz

appeal before th IS Court

The Pro Bono Committee is solely responsible for screening and selecting the civil cases for inclusion in the Program based upon a nun

discretionary criteria, including the financial means of the appellant or appellee, Ifa case is selected by the Committee, and can be mat

with appellate counsel, that counsel will take over representation of the appellant or appellee without charging legal fees More inform:

regarding this program can be found in the Pro Bono Program Pamphlet available in paper form at the Clerk's Office or on the Internet;

www tex-app.org If your case is selected and matched with a volunteer lawyer, you will receive a letter from the Pro Bono Committee

thirty (30) to forty-five (45) days after submitting this Docketing Statement.

Note there IS no guarantee that if you submit your case for possible inclusion in the Pro Bono Program, the Pro Bono Committee will SI

your case and that pro bono counsel can be found to represent you, Accordingly, you should not forego seeking other counsel to repres.

in this proceeding By signing your name below, you are authorizing the Pro Bono committee to transmit publicly available facts and

information about your case, including parties and background, through selected Internet sites and Listserv to its pool of volunteer appel

attorneys

Do you want this case to be considered for inclusion in the Pro Bono Program? DYes [j.No

Do you authorize the Pro Bono Committee to contact your trial counsel of record in this matter to answer questions the committee may f

regarding the appeal? 0 Yes 0 No

Please note that any such conversations would be maintained as confidential by the Pro Bono Committee and the information used solei'

the purposes of considering the case for inclusion in the Pro Bono Program, '

If you have not previously filed an affidavit ofIndigency and attached a file-stamped copy of that affidavit, does your income exceed 201

the Ll.S. Depa.trnent of Health and Human Services Federal Poverty Guidelines? [l Yes 0 No

These guidelines can be found in the Pro Bono Program Pamphlet as well as on the internet at http://asDe.hhs.~ov/Doverty/06poverty.sht

Are you willing to disclose your financial circumstances to the Pro Bono Committee? 0 Yes '0 No

If yes, please attach an Affidavit of Indigency completed and executed by the appellant or appellee, Sample forms may be found in the C

Office or on the internet at http://www,tex-app.org. Your participation in the Pro Bono Program may be conditioned upon your executioi

an affidavit under oath as to your financial circumstances.

Give a brief description of the issues to be raised on appeal, the relief sought, and the applicable .tar.dard of rev iew, if known <without

prejudice to me right to raise additional issues or request additional r.'k:f; use" separate attachment, if ne.',:::~ary).

XV. Signature

Date: G,- ('l-{C(

Printed Name:

J OS fhrtv~~

State Bar No l & ~t '1{?(l.l

Electronic Signature

(Optional) ~

Page 6 of 7
The undersigned counsel certifies that this docketing statement has been served on the following lead counsel for all parties to the trial

court's order or judgment as follows on

Person Served MARK TORABI

Certificate of Service Requirements (TRAP 9.S(e)): A certificate of service must be signed by the person who made the service and must

state:

Electronic Signature:

(Optional)

State Bar No.:

(I) the date and manner of service;

(2) the name and address of each person served, and

(3) if the person served is a party's attorney, the name of the party represented by that attomey

Please enter the following for each person served:

Date Served:

Manner Served:

First Name:

Middle Name:

Last Name:

Suffix:

TORABI

Law Firm Name:

Address I'

Address 2:

City:

State

Telephone:

Fax: 97'1. 967=StH7

Email:

If Attorney, Representing Party's Name: i'ROBIN CHRISTOPHER

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