Robert Edward Battaile v. Texas Elections Division, Hon. Jane Nelson; Texas Secretary of State; Jeffrey Travillion, Travis County Commissioner

ACCEPTED
15-25-00142-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
Cause No. 15-25-00142-CV 10/13/2025 12:00 AM
CHRISTOPHER A. PRINE
CLERK
IN THE FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS
FILED IN
15th COURT OF APPEALS
AUSTIN, TEXAS
ROBERT EDWARD BATTAILE, Appellant,
10/12/2025 10:34:17 PM
CHRISTOPHER A. PRINE
Clerk
v.

KEN PAXTON, ATTORNEY GENERAL OF TEXAS; JANE NELSON,

SECRETARY OF STATE OF TEXAS; AND REAL PARTIES IN INTEREST,

Appellees, et al.

From the 459th Judicial District Court of Travis County, Texas

Trial Cause No. D-1-GN-25-000719

APPELLATE BRIEF ON THE MERITS — ORAL ARGUMENT REQUESTED

TO THE HONORABLE JUSTICES OF THE FIFTEENTH COURT OF APPEALS:

Appellant Robert Edward Battaile, pro se, files this Appellate Brief on the Merits and

states his intent to appear personally and present oral argument at the time and place

designated by the Court. This brief consolidates all arguments and authorities supporting

relief in Cause No. 15-25-00142-CV and serves as both written brief and outline for oral

presentation.

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PRELUDE: THE REAL STORY BEHIND THE RECORD

This case is more than pleadings and citations. It is about the quiet capture of a small

Texas town — a modern fiefdom where public money follows private command, where

developers and their padrones whisper orders to city staff, and where those staff instruct

the City Council how to vote. The same names and families rotate through boards,

contracts, and campaign committees, while the people of Manor are left with broken

parks, demolished history, and promises that never reach the ground.

For decades, citizens have been told to stay silent. Those who question the deals or ask

for records are ridiculed, banned, or jailed. White pawns were replaced by Black and

Brown pawns, but the board never changed — only the faces moving under the same

thumb. The result is a government too frightened or too compromised to spend a single

dollar on preserving its heritage or building spaces of pride.

The State of Texas looks away. Travis County props the system up with selective

enforcement and hollow oversight. The Attorney General and Secretary of State ignore

election fraud, civil-rights violations, and horrific jail conditions. Citizens who speak out

face retaliation. Yet the bulldozers keep moving and the record remains blank.

This brief asks for something simple and profound — for law to mean something again

in small-town Texas. It asks the Court to look past procedural smoke and see the moral

truth: when government becomes a marketplace, parks are empty while history is erased

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and cemeteries desecrated; jails are a sub-human kennel whether innocent or guilty; and

justice is a court of no record... someone must stand up. That is why this case exists —

and why it matters.

TABLE OF CONTENTS

Prelude ….......................................................................................... 1

Identity of Parties and Counsel …..................................................... 4

Table of Authorities .......................................................................... 5

Statement of Jurisdiction ................................................................... 5

Issues Presented ................................................................................ 6

Statement of the Case and Facts ....................................................... 6

Summary of the Argument ............................................................... 7

Standard of Review .......................................................................... 7

Argument .......................................................................................... 8

I. Ministerial Election-Oversight Duties ...................................... 8

II. Irreparable Heritage Harm & Temporary Relief ..................... 8

III. Preserve Jury Rights on Independent Claims ......................... 8

IV. Structural Remedies & Record Integrity ................................ 9

V. Constitutional Baselines .......................................................... 9

Request for Oral Argument …......................................................... 9

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Request to include Appellant's public video publishing ….............. 10

Prayer for Relief ............................................................................... 10

IDENTITY OF PARTIES AND COUNSEL

Appellant: Robert Edward Battaile, pro se 502 E. Eggleston St., Unit B Manor, Texas

78653 Phone: 512-662-2955 Email: robert@manortx.us

Appellees: Ken Paxton, Attorney General of Texas Jane Nelson, Secretary of State of

Texas Represented by the Office of the Attorney General 300 W. 15th Street Austin,

Texas 78701

Real Parties in Interest (including dismissed defendants from underlying case, served via

eFile for notice of ongoing claims): State of Texas; City of Manor, Texas (dismissed, but

harms persist via successors); Travis County; Freese and Nichols (dismissed, but

Comprehensive Plan misuse continues); Legacy Performance Capital, LLC (dismissed

without prejudice); Manor MF LLC; Las Entradas; Monarch Ranch; MC Retail GP,

LLC; 13100 FM 973, Inc.; CapMetro; Carlos Moyeda; Dyana Limon-Mercado, Travis

County Clerk; Jeff Travillion, Travis County Commissioner; Brigid Shea, Travis County

Commissioner; Ann Howard, Travis County Commissioner; Margaret Gómez, Travis

County Commissioner; Matt Woodard, City of Manor Public Works Director; Sally

Hernandez, Travis County Sheriff; and others implicated in ultra vires acts, election

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coercion, historic desecration, or civil rights violations, as detailed in the Second

Amended Petition (CR [placeholder for Clerk's Record pages, e.g., 100-280]).

Counsel for Appellees and Active Real Parties: Office of the Attorney General (for

Paxton and Nelson) Travis County Attorney's Office (for Travis County entities) Other

counsel for dismissed parties. Bobby Ray Reese (real party in interest) and Austin Bocce

League (real party in interest).

TABLE OF AUTHORITIES

Cases

City of El Paso v. Heinrich, 284 S.W.3d 366 (Tex. 2009)

City of San Antonio v. Kaur, 574 S.W.3d 595 (Tex. App.—San Antonio 2019, no pet.)

In re Hotze, 627 S.W.3d 642 (Tex. 2020)

Walker v. Packer, 827 S.W.2d 833 (Tex. 1992)

Statutes / Rules

Tex. Const. art. I (Open Courts; Due Course)

Tex. Elec. Code §§ 31.003, 273.001, 273.021, 232.012

Tex. Gov’t Code §§ 22.220, 22.221

Tex. Health & Safety Code § 711.010

Tex. R. App. P. 9.4, 9.5, 52; Tex. R. Civ. P. 171

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STATEMENT OF JURISDICTION

This Court has jurisdiction under Tex. Gov’t Code §§ 22.220 and 22.221 and Tex. R.

App. P. 52.3(e). Because Appellees are statewide officers and Appellant seeks relief of

statewide importance arising from Travis County proceedings, this Court properly

exercises jurisdiction.

ISSUES PRESENTED

1.Whether the Secretary of State and Attorney General failed to perform

ministerial duties under the Election Code.

2.Whether temporary injunctive relief is needed to preserve the 1906 Martin

McVey Cemetery and the James B. Manor Homestead.

3.Whether Appellant’s constitutional and civil-rights claims must be preserved for

jury trial.

4.Whether persistent procedural failures justify appointment of a Special Master

and record-integrity orders.

STATEMENT OF THE CASE AND FACTS

Appellant contests the Nov. 2024 Manor municipal election for ballot denial, coercion,

and irregularities. Formal complaints to the SOS and AG produced no confirmed

investigation or public result. Public Information requests were stonewalled or answered

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with “no responsive records.”

In the trial court, dozens of motions remain unruled. Court Recordings delivery was

interminable despite being requested at the hearings themselves. A Court Reporter from

May requested and got an extension causing a delay in the appeals transition. One

hearing not recorded at all (i.e. a Court of No Record). Orders were entered without

findings or reasoned explanations. The record is incomplete and opaque.

Meanwhile, the 1906 Martin McVey Cemetery and the 1840s James B. Manor

Homestead are threatened by ongoing development approved without historic review.

City funds were used to clear private lots while police ignored desecration reports.

Appellant has been arrested twice for speaking out and endured inhumane conditions in

Travis County Central Booking — facts that speak to retaliation and the denial of basic

due process.

SUMMARY OF THE ARGUMENT

Texas law already provides the tools to fix these wrongs. When statewide officers ignore

clear duties, and local courts leave motions unruled for months, mandamus-level relief is

the only adequate remedy. Short TROs can prevent irreparable damage to burial grounds

and historic sites. Jury rights must be preserved for independent constitutional claims.

And a Special Master should be appointed to restore record integrity and public

confidence.

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STANDARD OF REVIEW

Under Walker v. Packer, 827 S.W.2d 833 (Tex. 1992), mandamus issues for a clear

abuse of discretion where no adequate remedy exists. Failure to perform a ministerial

duty meets that standard.

ARGUMENT

I. Ministerial Election-Oversight Duties

The Texas Election Code (§§ 31.003, 273.001, 273.021) requires state officers to receive

and act on election complaints. Appellant's submissions remain unacknowledged. This

Court should order the SOS and AG to confirm whether any investigation occurred,

disclose non-privileged results, and perform the statutory steps necessary to remedy the

Nov. 2024 Manor election.

II. Irreparable Heritage Harm and Need for TROs

The record documents imminent destruction of the McVey Cemetery and Manor

Homestead. Under Tex. Health & Safety Code § 711.010, cemeteries are sacred grounds

not to be disturbed without court authority. A 45-day TRO is the least-restrictive means

to protect evidence and honor. This Court may issue temporary orders to preserve its

jurisdiction.

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III. Preserve Jury Rights on Independent Claims

The election contest is bench-tried, but Appellant's § 1983 and constitutional claims —

retaliation, due process, equal protection — are independent and jury-triable. See City of

El Paso v. Heinrich, 284 S.W.3d 366 (Tex. 2009). Rule 91a cannot extinguish those

rights before discovery. This Court should order severance or phasing to preserve the

jury.

IV. Structural Remedies and Record Integrity

Months of unruled motions and missing transcripts demand a Special Master under Tex.

R. Civ. P. 171 to coordinate heritage preservation, marshal records, and report to the

Court. Without record integrity, appeal is meaningless.

V. Constitutional Baselines

“Courts of no record” and inhumane detention conditions violate due process and the

open-courts guarantee. This Court should direct record preservation and minimum

process standards to protect the right to review.

REQUEST FOR ORAL ARGUMENT

Pursuant to Rule 39.7(a). Request and Waiver (Texas Rules of Appellate Procedure)

Appellant respectfully requests oral argument. This case raises questions of statewide

importance involving ministerial duties of state officials, historic-site preservation, and

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citizens’ rights in local governance. Appellant believes oral presentation will assist the

Court and confirms his readiness to appear personally to present argument.

REQUEST FOR VIDEO EVIDENCE REVIEW

Attached as Exhibit A to the Appendix is a list of Appellant's YouTube videos, and a

portion of a police video documenting the relevant city council public comments and

parkland public trust harms; along with an affidavit authenticating the videos as true and

accurate depictions of the proceedings. A copy of the videos on disc is provided to the

Clerk of the Court for the Court's review. The videos demonstrate the council's approval

of developments threatening the Martin McVey Cemetery and James B. Manor

Homestead without required historic review or open meetings compliance under Texas

Government Code Chapter 551, including verification codes from the official council

archives for authentication. These materials support the claims of procedural failures,

retaliation, and irreparable harm detailed herein.

PRAYER FOR RELIEF

Appellant respectfully prays that this Court grant the following relief:

1. If given the family's wishes and blessing ~ Donald McVade be buried

immediately at his likely Great-great-grandfather, Martin McVey's (Vey, Vade)

1906 Cemetery re-discovered adjacent to the 1861 Manor Cemetery; and a block

from the family home Donald lived in.

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2.Election Oversight & Investigation

•Compel the Secretary of State and Attorney General to receive, investigate,

and act on Appellant's election complaints, disclose whether an

investigation occurred, and provide non-privileged results.

•Order waiver or cost reduction and production of Manor PD public records

related to investigation (PIA/FOIA compliance).

3.Structural & Procedural Remedies

•Exercise original jurisdiction to oversee this cause.

•Appoint a Special Master and/or tribunals (Reparations & Historic Justice;

Parks & Recreation Public Trust) to coordinate fact-gathering, monitor

compliance, and report to this Court.

•Require prompt rulings or hearings on all outstanding motions (transcripts,

preservation, immunity waiver, preservation TROs).

•Ensure proper notice/eService to all real parties, including previously

dismissed proper parties still implicated by ongoing harms.

4.Heritage & Historic Protection Injunctions / TROs

•Issue 45-day TROs preserving the McVey Cemetery, 1871 Manor

Cemetery, James B. Manor Homestead, and all parcels within the Old

– 11 – 15-25-00142-CV
Manor Historic District, halting any grading, demolition, or construction

pending GPR, boundary determination, or substantive hearings.

•Extend injunctive protection to the Manor Downs Raceway / warehouse

redevelopment site(Dalfen/Manor Downs), enjoining demolition, grading,

or construction until this Court reviews public-trust, historic, zoning, and

environmental compliance.

5.Main Street / Historic District Projects

•Enjoin MAQIL / Manor Grocery from demolition or structural alterations

pending historic review.

•Enjoin BuildBlock / Boyce Street improvements until Code, historic-

impact, and procedural compliance is audited.

6.Public-Trust & Chapter 380 / 381 Remedies

•Declare unlawful subsidies under Chapter 380 used to defraud citizens;

rescind or recover those funds.

•Enforce public-trust obligations: require creation or restoration of

parkland, plazas, trails, and community amenities promised in development

agreements (HEB/Manor Commons, Monarch Ranch, ShadowGlen).

•Order injunctive and accounting relief so that developers and the City

deliver what was contractually / statutorily promised.

– 12 – 15-25-00142-CV
7.Transit / CapMetro / Travis County Relief

•Order disclosure of CapMetro/Travis County agreements.

•Require refund or accounting for transit services not delivered (weekend

service withheld).

•Mandate free transit or special service to polling sites.

8.Police Accountability / Civil-Rights Relief

•Order investigation and accountability for retaliatory arrests of Appellant.

•Enforce police department records disclosure, reform or oversight.

•Grant damages, costs, and fees for constitutional violations (speech,

petitioning, retaliation, due process).

9.Site-Specific / Appendix-Based Remedies

•Enforce or restore relief for Manor Crossing / H-E-B (plaza, parkland,

Chapter 380 compliance).

•Enforce Manor Commons plaza / public amenities compliance.

•Enforce Monarch Ranch parkland/trail obligations.

•Require completion and dedication of ShadowGlen trails or parks.

•Award damages and restoration for the Bocce Court destruction.

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•Support Reparations for Old Manor related to historic erasure and neglect.

•Enjoin further work on any parcels implicated by the uploaded Appendix 1

Rev-1 until reviewed.

10. General & Further Relief

•Grant all other legal and equitable relief, including restitution of misused

public funds, attorneys’ fees (if applicable), interest, and any orders needed

to protect cemeteries, historic resources, parklands, public-trust properties,

and citizens’ rights under both Texas and U.S. Constitutions.

Reservation Regarding Errors and Omissions. Appellant proceeds pro

se and has assembled this record in good faith. To the extent any citation,

exhibit, or argument has been inadvertently omitted or mis-cited despite

diligence, Appellant respectfully requests leave to correct and supplement.

Respectfully submitted this 12th day of October, 2025, by

/s/ Robert Edward Battaile

Robert Edward Battaile, Appellant Pro Se

502 E Eggleston St Unit B

– 14 – 15-25-00142-CV
Manor TX 78653

512-662-2955

robert@manortx.us

CERTIFICATE OF COMPLIANCE

This brief complies with Tex. R. App. P. 9.4(i) and contains approximately 1,757 words

excluding exempt sections. Prepared in 14-point Times New Roman, double-spaced,

with 1-inch margins.

CERTIFICATE OF SERVICE

I certify that on October 12, 2025, a true and correct copy of this Appellate Brief on the

Merits — Oral Argument Requested was served via eFileTexas and by certified mail on

all parties and real parties in interest appearing of record.

Respectfully submitted,

/s/ Robert Edward Battaile
Robert Edward Battaile, Appellant Pro Se
502 E Eggleston St Unit B
Manor TX 78653
512-662-2955
robert@manortx.us

– 15 – 15-25-00142-CV
EXHIBIT A. VIDEO EVIDENCE

Note that after the Covid restrictions regarding in-person city council meetings were

lifted; there was no videotaping being done by the City. Only after Appellant began

going to meetings, videotaping and posting these videos on youtube did the City of

Manor began doing this important transparency and engagement chore of “live

streaming” and video archiving council, commission and committee meetings.

1. Moore Lies On Police Body Cam https://youtu.be/1tYU6IVVV8k Duration: 01:38

Published Dec 29, 2024. Authentication Code: YT-AUTH-001 (video ID:

1tYU6IVVV8k; self-authenticated via unsworn declaration referencing personal

recording of police body cam footage) Summary: City Manager, Scott Moore

demonstrates bias in interaction captured on police body cam, highlighting procedural

irregularities in Manor TX governance.

2. Robert's "State of the City of Old Manor, Texas"

https://youtu.be/VT2MKp7rdl8 Duration: 27:47 Authentication Code: YT-AUTH-002

(video ID: VT2MKp7rdl8; self-authenticated via unsworn declaration as personal

address on local issues) Summary: Relator's State of the City address exposing systemic

problems in Old Manor, including heritage neglect and election concerns.

3. Manor Texas Parks and Wreck Proclamation https://youtu.be/lN3b_MeVtvE

Duration: 13:11 Authentication Code: YT-AUTH-003 (video ID: lN3b_MeVtvE; self-

– 16 – 15-25-00142-CV
authenticated via unsworn declaration tying to Parks Dept. absence)

Summary: Proclamation on the non-existence of Manor TX Parks and Rec Department,

linking to broken promises on public amenities.

4. Reverse Discrimination in Manor Texas https://youtu.be/ruSfKd7jfog Duration: 03:20

(estimated; verify from disc) Upload Date (Metadata): 2024-05-05 (approximate;

confirm via YouTube or disc metadata)Authentication Code: YT-AUTH-004 (video ID:

ruSfKd7jfog; self-authenticated via unsworn declaration on discrimination

claims) Relevance Summary: Discussion of reverse discrimination practices in Manor

TX, supporting civil rights arguments in the brief.

5. Bocce Revenge in Manor Texas https://youtu.be/C2KYN2StaP8 Duration: 05:07

Authentication Code: YT-AUTH-005 (video ID: C2KYN2StaP8; self-authenticated via

unsworn declaration referencing contract breach) Summary: City's declaration of bocce

court as a "Public Health and Safety Hazard" to justify contract breach and destruction.

6. Robert Unlawfully Escorted from Manor Texas Council Meeting

https://youtu.be/OXRaIDwgOXk Duration: 02:06 Authentication Code: YT-AUTH-006

(video ID: OXRaIDwgOXk; self-authenticated via unsworn declaration as evidence of

retaliation) Summary: Footage of Relator being unlawfully escorted from a council

meeting, evidencing First Amendment violations.

7. Short Squat Texan (Small Clown Car) - lyrics version.

https://youtu.be/N7u395P9yeg Duration: 03:40 Authentication Code: YT-AUTH-007

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(video ID: N7u395P9yeg; self-authenticated via unsworn declaration as parody on local

politics) Summary: Relator's parody song critiquing Manor TX leadership, used as

protected speech in constitutional claims.

8. Robert Truthsayer Teaches Manor City Council - Lesson 2

https://youtu.be/jacJEHfnL_4 Duration:03:10 Authentication Code: YT-AUTH-008

(video ID: jacJEHfnL_4; self-authenticated via unsworn declaration on Monarch Ranch

issues) Summary: Lesson on Monarch Ranch's failure to deliver parkland and in-lieu

fees, totaling acres and hundreds of thousands in funds.

9. Robert teaching Manor Texas City Council - Lesson 1 - 12-21-22

https://youtu.be/tycI6v1ZOEc Duration: 02:05 Authentication Code: YT-AUTH-009

(video ID: tycI6v1ZOEc; self-authenticated via unsworn declaration from council

meeting) Summary: First lesson to City Council on governance failures, dated December

21, 2022, supporting record integrity claims.

10. Disc Golf Course for Manor TX https://youtu.be/R_4Eh7QTZzA Duration: 05:57

Authentication Code: YT-AUTH-010 (video ID: R_4Eh7QTZzA; self-authenticated via

unsworn declaration proposing public amenity) Summary: Proposal for free disc golf

course rejected by City Council three years ago, exemplifying neglect of public

recreation.

– 18 – 15-25-00142-CV
Exhibit B. Col Eppright Deed Trail without mention of Texas A&M Land Gift. (from

Wayne Schneider manorstories@blogspot.com)

– 19 – 15-25-00142-CV
Exhibit C. Historic Map of Homestead and Stagecoach Route to Austin

– 20 – 15-25-00142-CV
Exhibit D. Plazas missing from two Developers.

NW Corner of 290 and 973: 13100 FM 973 Inc. as “Manor Crossing” (Home Depot,

HEB, etc). NE Corner is Barth Timmermann's Greenview “Manor Commons.” As

commercial developments over ten acres, both are required to provide “plazas.”

(This downloaded google map photo from today, 10-12-25... is a couple of years old)

– 21 – 15-25-00142-CV
Exhibit E. Map of original lots split equally between railroad and Mr. Manor.

Red lots were given to the Railroad by James Manor. That's the reason the

Houston and Central Texas Railroad came here to Manor. Not the other way

around. The Founder, James B. Manor is becoming the Forgotten Man.

– 22 – 15-25-00142-CV
Exhibit F. Early Manor survey

– 23 – 15-25-00142-CV
Exhibit G. Manor Downs acceptable Warehouse Park; and map to Manor's

existing “Commercial Park” a mere four miles away and more central to the ETJ.

– 24 – 15-25-00142-CV
Exhibit H. UNSWORN DECLARATION OF ROBERT EDWARD BATTAILE

Pursuant to Section 132.001 of the Texas Civil Practice and Remedies Code, I, Robert

Edward Battaile, declare under penalty of perjury that the foregoing is true and correct.

1. My name is Robert Edward Battaile. I am over 18 years of age, of sound mind,

and capable of making this declaration. I am the Appellant in Cause No. 15-25-

00142-CV, pending in the Fifteenth Court of Appeals, Austin, Texas. I have

personal knowledge of the facts stated, and they are true and correct.

2. The YouTube videos listed in Exhibit A to the Appendix are true and accurate

recordings of the specified City of Manor council meetings and proceedings;

parkland and in-lieu parkland fees thefts, bocce court harms and more. These

youtube videos and links were included during the past three years in the

Appellant's “MANOR TX” Email Newsletter publishing once or twice weekly to

150-300 local citizens including City Council and Staff, Manor PD, Chamber of

Commerce, Manor ISD, Churches, County Commissioners, Austin and other local

city councils and mayors, along with an anonymous local list; and national media

and social influencers. Only a handful of recipients have asked to be removed.

3. This is the Robert's Freedom of the Press and Freedom of Speech email list that

Appellant got thrown in jail for... twice. They BOTH originated in Texas “Courts

of No Record.” Onc charge was alleged by the City Manager, and one charge was

alleged by the City Secretary for email “Harassment” with an $8,000 bail and

– 25 – 15-25-00142-CV
stay-away conditions that cobbled Appellant's Mayoral campaign. And, also one

later arrest for alleged email “Stalking Charges” brought by the Police Chief with

a $30,000 bail. Both bails were reduced to zero. The three charges were

DISMISSED entirely citing insufficient evidence and two citing “Owens v State.”

4. I personally attended the included meetings and can attest that the videos taken

by me with my video equipment represent the events, including discussions on

election irregularities, development approvals threatening historic sites like the

Martin McVey Cemetery and James B. Manor Homestead, and related procedural

violations. Note that Appellant's journalistic editing and political commentary;

and sarcasm are often plainly and unapologetically included. City of Manor has no

unbiased local newspaper. The Police footage showing City Manager's intrinsic

bias is authentic and unaltered.

5. A complete, unaltered copy of these videos will be provided on a digital drive

labeled "Exhibit A - Council Video Records," which matches the YouTube

versions exactly and is submitted to the Clerk of the Court for review.

Executed on October 12, 2025.

/s/ Robert Edward Battaile
Robert Edward Battaile Appellant, Pro Se
502 E Eggleston St Unit B Manor, TX 78653
512-662-2955 robert@manortx.us

– 26 – 15-25-00142-CV
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Envelope ID: 106743888
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Case Contacts

Name BarNumber Email TimestampSubmitted Status

Jeffrey Hobbs 24012837 jhobbs@abaustin.com 10/12/2025 10:34:17 PM SENT

Michael Kabat 24050847 mkabat@mcginnislaw.com 10/12/2025 10:34:17 PM SENT

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Patrick Kelly 11228000 pat.kelly@traviscountytx.gov 10/12/2025 10:34:17 PM SENT

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Edward Smith 24037790 esmith@808west.com 10/12/2025 10:34:17 PM SENT

Robert EdwardBattaile robert@manortx.us 10/12/2025 10:34:17 PM SENT

Annette Bittick abittick@mcginnislaw.com 10/12/2025 10:34:17 PM SENT

Patricia Muniz paralegal@rigbyslack.com 10/12/2025 10:34:17 PM SENT

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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: 106743888
Filing Code Description: Brief Requesting Oral Argument
Filing Description: Brief with Oral Argument
Status as of 10/13/2025 6:53 AM CST

Case Contacts

Raylynn Howell raylynn.howell@bakerbotts.com 10/12/2025 10:34:17 PM SENT

Kim McBride kmcbride@mcginnislaw.com 10/12/2025 10:34:17 PM SENT

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Carol Shipley cshipley@rrspllc.com 10/12/2025 10:34:17 PM SENT

Emily Hill ehill@manortx.gov 10/12/2025 10:34:17 PM SENT

Anne Weir aweir@manortx.gov 10/12/2025 10:34:17 PM SENT