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
10/20/2025 12:00 AM
CAUSE NO. 15-25-00142-CV CHRISTOPHER A. PRINE
CLERK
FILED IN
IN THE FIFTEENTH COURT OF APPEALS 15th COURT OF APPEALS
AUSTIN, TEXAS
10/20/2025 12:00:00 AM
AUSTIN, TEXAS CHRISTOPHER A. PRINE
Clerk

ROBERT EDWARD BATTAILE, Appellant Pro Se

v.

STATE OF TEXAS ELECTIONS DIVISION, et al., Appellees

SUPPLEMENT TO LETTER CLARIFYING NUMBER OF

DEFENDANTS

TO THE HONORABLE JUSTICES OF THE FIFTEENTH COURT OF

APPEALS:

Appellant files this supplement to his October 17, 2025 Letter to the Court

described as “Letter re wrong number of Defendants in Court Order” to

provide concise clarification regarding the actual structure of the parties

named in this matter.

–1– 15-25-00142-CV
The Court’s October 16 Order referenced “approximately forty-two

defendants.” That figure is not accurate when considered in legal context.

Each set of individuals was named in official capacity only and represents a

single governmental or corporate entity. When grouped by entity, there are

eighteen (18) distinct defendant entities or real parties in interest,

summarized below:

1. State of Texas – Ken Paxton (Attorney General); Jane Nelson

(Secretary of State) – Official capacities for ignoring election fraud

and suppressing FOIA requests re: Election Investigation. Also re

Jail conditions and ending statewide Courts of No Record that lack

due process and transparency.

2. Travis County – Commissioners Travillion, Howard, Shea,

Gómez, and Judge Brown; Sheriff Sally Hernandez; County

Attorney Dyana Mercado; right of first refusal for city to purchase

Clayton Vocational Institute (county-owned historic property).

Also for ignoring Election Coercion issues; ignoring “Public

Health and Safety” bogus claims used to breach contract with

–2– 15-25-00142-CV
Austin Bocce League; ignoring Cemetery Desecration and Police

Misconduct.

3. CapMetro – Capital Metropolitan Transportation Authority –

quasi-governmental transit authority under Travis County

oversight. Deceptive trade practice during approval process by not

disclosing they would be charging for but not running on

weekends. Commissioner Travillion is Chairman of the Board.

4. City of Manor – Mayor Harvey; six Council Members; City

Manager Leslie Moore; City Secretary Lluvia Almaraz; Public

Works Director; former Heritage & Tourism Manager; Police

Chief Phipps, officers and two former officers. Election Coercion

and numerous claims of police misconduct and coverups, civil

rights violations, historic destruction of landmarks, allowing

parkland thefts of land and money; plus retaliation and false

imprisonment. City has been operating without a legal Council

quorum since November election fraud.

–3– 15-25-00142-CV
5. Freese & Nichols, Inc. – Authors of the faulty Comprehensive

Plan used to destroy historic Manor, and for never holding the

town hall meetings or finishing the project they were paid for.

6. Legacy Performance Capital LLC – Developer of townhomes on

historic 1906 Martin McVey Cemetery site including misuse of

city funds to clear land and desecrating said cemetery.

7. Las Entradas Development LLC – Developer of the 1840's

James B Manor Homestead tract linked to the Col. Eppright estate,

and need to protect remaining fragile shacks.

8. Manor MF LLC – Developer of apartments on the James B.

Manor Homestead tract purchased from Las Entradas. Plaintiff

sought emergency injunctive relief to protect the historic site,

but Judge Soifer prevented the filing or consideration of Plaintiff’s

ex parte application for a Temporary Restraining Order (TRO),

allowing demolition and site work to proceed despite pending

preservation concerns.

–4– 15-25-00142-CV
9. Maqil Inc. – Seeking zoning changes for Manor Grocery site

inconsistent with historic Main Street; alleged false PO Box and

misrepresentation on zoning filings.

10. Manor ISD – Owner of historic school property (former

Parson’s School for Girls / Masonic Lodge #222) that is currently

an abandoned school. Right of first refusal sought.

11. Buildblock.io – Developer of overpowering live-work-play

apartments/offices inconsistent within the Historic District.

12. Carlos Moyeda – Demolition of historic mansion at 104 E.

Townes Street; and future building approvals/restrictions.

13. 13100 FM 973 Manor Crossing shopping center for Chapter

380 violations – Includes (a) HEB – Plaza obligation; (b) Park at

Manor Crossing Apartments – parkland fee violations; (c) Manor

Retail GP – sales tax and public space obligations.

14. Meritage Homes of Texas LLC – ShadowGlen development;

unpaid parkland fees, parkland dedication and trail installs.

–5– 15-25-00142-CV
15. Manor Commons LLC – Retail mixed-use project over ten

acres with unfulfilled plaza requirement.

16. Dalfen Industrial / DG Manor Downs LP – Industrial park

replacing historic Manor Downs racetrack, destroying heritage

trees, environmental issues, traffic mitigations and needless 380

grants claimed as “incentives” worth millions of dollars.

17. Texas A&M Foundation – Initially a record custodian; treated

as Defendant pending full compliance with Public Information Act

requests regarding Homestead and Eppright tracts.

18. Travis Central Appraisal District (TCAD) – Non-party

resource for property records and agricultural-use exemptions.

Appellant further clarifies that certain non-defendant parties appear in the

record for context and standing purposes.

• Bobby Reese, submitted to be a candidate for Manor City Council but

was unlawfully prevented from appearing on the ballot—an event central to

Appellant’s Election Contest and claims of election coercion, voter

disenfranchisement, and ultra vires conduct by state and municipal officials.

–6– 15-25-00142-CV
• Austin Bocce League, a nonprofit organization operated by Appellant,

appears as a contractual and equitable claimant in relation to the City of

Manor’s breach of its Licensing Agreement, implied park-improvement

commitments and failure to provide designated public recreation space.

These parties are included for factual context and standing, but they are not

defendants in the underlying cause. Their interests illustrate the public-trust

and contractual dimensions of this litigation.

Appellant respectfully submits that, although more than forty individual

names appear throughout the pleadings, these individuals operate within the

eighteen (18) discrete entities identified above. Each entity functions as the

real party in interest for service, liability, and appellate review. The earlier

reference in the Court’s order to “approximately forty-two defendants”

therefore misstates the operative structure of the case.

This clarification is filed while the Court retains plenary authority under

Texas Rule of Appellate Procedure 19.1 to correct clerical and factual errors

for accuracy in the record. This is a best efforts summary not intended to

limit any impacts that may have been inadvertently omitted in error.

–7– 15-25-00142-CV
Respectfully submitted on October 18, 2025 by

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

CERTIFICATE OF SERVICE

I certify that on October 18, 2025, a true and correct copy of this

Supplement was served via e-service through the eFileTexas system on all

counsel and parties of record / appellees / defendants, including by mail to

Dalfen Industries, and Texas A&M Foundation.

Maqil Inc furnished incorrect address information to TCAD and cannot be

noticed at present. Appellant has filed Public Information Request PIR-264-

2025 with City of Manor for the owner's accurate information and has

emailed Manor Grocery owner's Project Designer, Chris Garcia

Chris22garcia90@gmail.com in an attempt to gather this information.

/s/ Robert Edward Battaile

Robert Edward Battaile, Appellant Pro Se

–8– 15-25-00142-CV
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: 107015646
Filing Code Description: Other Document
Filing Description: SUPPLEMENT TO LETTER CLARIFYING NUMBER
OF DEFENDANTS
Status as of 10/20/2025 7:03 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Jeffrey Hobbs 24012837 jhobbs@abaustin.com 10/18/2025 6:44:31 PM SENT

Michael Kabat 24050847 mkabat@mcginnislaw.com 10/18/2025 6:44:31 PM SENT

Joanna Salinas 791122 joanna.salinas@fletcherfarley.com 10/18/2025 6:44:31 PM SENT

William Davidson 5447000 bdavidson@chmc-law.com 10/18/2025 6:44:31 PM SENT

Gavin Villareal 24008211 gavin.villareal@bakerbotts.com 10/18/2025 6:44:31 PM SENT

Michael Roberts 24082153 mroberts@jw.com 10/18/2025 6:44:31 PM SENT

Cynthia Veidt 24028092 cynthia.veidt@traviscountytx.gov 10/18/2025 6:44:31 PM SENT

Stephanie Serrano 24092655 sserrano@rothberg.law 10/18/2025 6:44:31 PM SENT

Kevin O'Hanlon 15235500 kohanlon@808west.com 10/18/2025 6:44:31 PM SENT

Patrick Kelly 11228000 pat.kelly@traviscountytx.gov 10/18/2025 6:44:31 PM SENT

Tyler Ryska 24096597 tryska@rigbyslack.com 10/18/2025 6:44:31 PM SENT

Austin Jones 24116579 ajones@mcginnislaw.com 10/18/2025 6:44:31 PM SENT

William Duncan 24124453 wduncan@rigbyslack.com 10/18/2025 6:44:31 PM SENT

Roy Adams roy.adams@oag.texas.gov 10/18/2025 6:44:31 PM SENT

Tristan AGarza tristan.garza@oag.texas.gov 10/18/2025 6:44:31 PM SENT

Lauren Bush 24142742 lbush@jw.com 10/18/2025 6:44:31 PM SENT

Anna Puff 24144206 apuff@sneedvine.com 10/18/2025 6:44:31 PM SENT

Edward Smith 24037790 esmith@808west.com 10/18/2025 6:44:31 PM SENT

Robert EdwardBattaile robert@manortx.us 10/18/2025 6:44:31 PM SENT

Annette Bittick abittick@mcginnislaw.com 10/18/2025 6:44:31 PM SENT

Patricia Muniz paralegal@rigbyslack.com 10/18/2025 6:44:31 PM SENT

Raylynn Howell raylynn.howell@bakerbotts.com 10/18/2025 6:44:31 PM SENT
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: 107015646
Filing Code Description: Other Document
Filing Description: SUPPLEMENT TO LETTER CLARIFYING NUMBER
OF DEFENDANTS
Status as of 10/20/2025 7:03 AM CST

Case Contacts

Raylynn Howell raylynn.howell@bakerbotts.com 10/18/2025 6:44:31 PM SENT

Kim McBride kmcbride@mcginnislaw.com 10/18/2025 6:44:31 PM SENT

Lea Ohrstrom lohrstrom@808west.com 10/18/2025 6:44:31 PM SENT

Sneed Vine &Perry gtwnfilings@sneedvine.com 10/18/2025 6:44:31 PM SENT

Stormy Downing sdowning@rrspllc.com 10/18/2025 6:44:31 PM SENT

Andy Soule asoule@rrspllc.com 10/18/2025 6:44:31 PM SENT

Karah Powers kpowers@chmc-law.com 10/18/2025 6:44:31 PM SENT

Martha AnnAdams madams@abaustin.com 10/18/2025 6:44:31 PM SENT

Benjamin C. Hunt ben.hunt@bakerbotts.com 10/18/2025 6:44:31 PM SENT

Eldridge Burns eburns@rrspllc.com 10/18/2025 6:44:31 PM SENT

Amy Botelho abotelho@mcginnislaw.com 10/18/2025 6:44:31 PM SENT

Carol Shipley cshipley@rrspllc.com 10/18/2025 6:44:31 PM SENT

Emily Hill ehill@manortx.gov 10/18/2025 6:44:31 PM SENT

Anne Weir aweir@manortx.gov 10/18/2025 6:44:31 PM SENT