In Re Cedric M. Scott, PhD v. the State of Texas

ACCEPTED
15-25-00227-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
12/9/2025 1:24 AM
CHRISTOPHER A. PRINE
CLERK
FILED IN
IN THE FIFTEENTH COURT OF APPEALS
15th COURT OF APPEALS
AUSTIN, TEXAS
AT AUSTIN, TEXAS 12/9/2025 1:24:20 AM
CHRISTOPHER A. PRINE
Clerk

Case No. 15-25-00227 - CV
(Transferred from the Third Court of Appeals)

IN RE CEDRIC M. SCOTT, PhD
Relator, Pro Se

v.

GENERAL LAND OFFICE OF THE STATE OF TEXAS
Real Party of Interest

Original Proceeding from the 250th Judicial District Court
of Travis County, Texas
Trial Court Cause No. D-1-GN-25-000006

RELATOR’S MOTION FOR EMERGENCY RELIEF
TO THE HONORABLE FIFTEENTH COURT OF APPEALS:

Relator, Cedric M. Scott, PhD1, respectfully requests this Court for

emergency temporary relief under Texas Rule of Appellate Procedure 52.10 to

preserve her rights and prevent irreparable harm while the Court considers her

Petition for Writ of Mandamus filed December 5, 2025 and accepted for filing on

December 8, 2025.

Emergency intervention is necessary because the orders issued by former

presiding Judge Cory R. Liu—including orders compelling Relator’s deposition,

denying dispositive motions, and affecting the procedural posture of the case—

were issued while Judge Liu was constitutionally disqualified from the onset this

whistleblower case. As such, the orders are void ab initio, and enforcement of

them would inflict additional irreparable harm on Relator, who currently has no

successor trial judge available to correct or vacate the void orders.

I. RELIEF REQUESTED

Under TRAP 52.10, Relator respectfully requests that this Court:

1. Stay enforcement of all orders issued by Judge Cory R. Liu in Cause
No. D-1-GN-25-000006, including but not limited to:

• The order compelling Relator to appear for deposition,

1
Plaintiff’s first name is pronounced See-Drick and not Said-Drick. Gender is female, and pronouns are
she, her, and hers.

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• The order setting hearings on motions,

• The denial of Relator’s dispositive motions, and

• Any procedural directives affecting Relator’s rights.

2. Preserve the status quo by prohibiting GLO or its counsel from attempting

to enforce or rely upon the void orders pending this Court’s final resolution

of the mandamus.

3. Order the Real Party in Interest not conduct any deposition, hearing,

conference, or other litigation activity based on orders issued by Judge Liu

while disqualified.

4. Grant any further emergency relief necessary to protect the Court’s

jurisdiction and prevent further irreparable harm.

II. EMERGENCY RELIEF IS NECESSARY TO PREVENT
IRREPARABLE HARM

Emergency relief is appropriate where temporary orders are needed to

protect the Court’s jurisdiction or prevent harm that cannot be remedied on

appeal. Tex. R. App. P. 52.10(a).

A. Enforcement of Void Orders Constitutes Irreparable Harm

Under Tex. Const. art. V, §11, a judge who previously represented a party is

constitutionally disqualified. Orders issued during disqualification are:

• Void,

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• Unenforceable, and

• Subject to mandamus relief.

See Buckholts I.S.D. v. Glaser, 632 S.W.2d 146, 148–49 (Tex. 1982).

Requiring Relator to comply with void orders—especially a compelled

deposition order—would inflict harm that cannot be cured through appellate

review, satisfying the standard for temporary relief.

B. Relator Has No Functional Trial Court

Judge Liu recused himself on November 21, 2025, and as of this filing:

• No successor judge has been appointed,

• Void orders remain unaddressed, and

• The trial court is unable to act.

Relator thus has no avenue to seek relief in the trial court, satisfying the

requirement that emergency intervention is necessary to preserve her rights.

C. Continued Delay Compounds Professional and Financial Harm

Relator has been without comparable employment since December 3, 2024

and continues to experience ongoing blacklisting. Every additional week of

litigation paralysis:

• Compounds economic loss,

• Delays relief under the Texas Whistleblower Act, and

• Worsens the prejudice caused by void orders and procedural breakdown.

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The Texas Supreme Court recognizes that where “delay will permanently

prejudice the rights of the parties,” emergency relief may be warranted. In re

McAllen Med. Ctr., 275 S.W.3d 458, 466 (Tex. 2008).

III. EMERGENCY RELIEF IS NECESSARY TO PRESERVE THE
COURT’S JURISDICTION

If the Court does not issue a temporary stay, GLO may attempt to:

• Enforce the void deposition order,

• Continue litigation activity without judicial authority,

• Take actions premised on void rulings, or

• Create additional procedural complications that frustrate appellate

review.

Issuing temporary relief under TRAP 52.10 prevents the Real Party from

relying on void orders in a manner that could moot or undermine the mandamus.

IV. REQUEST FOR TEMPORARY RELIEF WITHOUT PRIOR
NOTICE

Under Texas Rule of Appellate Procedure 52.10(b), the Court may grant

temporary relief without prior notice where immediate intervention is necessary

to prevent irreparable injury or to protect the Court’s jurisdiction. This is such a

case. Relator respectfully submits that emergency relief without prior notice is

warranted because:

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1. There is currently no successor judge to whom Relator can apply for

vacatur of the void orders. Since Judge Liu’s recusal on November 21, 2025,

the trial court has been unable to act, leaving Relator without any avenue for

relief at the trial-court level.

2. All operative orders were issued by a constitutionally disqualified judge,

rendering them void ab initio. Enforcement of void orders constitutes

immediate and irreparable harm that cannot be remedied on appeal.

3. The compelled deposition order presents imminent harm because GLO

intends to enforce a deposition, notwithstanding Judge Liu’s disqualification

and the absence of judicial oversight. Requiring Relator to comply with a

void deposition order would undermine the integrity of the judicial process

and prejudice the mandamus proceeding itself.

4. The Real Party in Interest continues to benefit from procedural paralysis,

while Relator continues to suffer ongoing blacklisting, loss of comparable

employment, and increasing prejudice with each week of delay.

5. Temporary relief is necessary to preserve the status quo so that the Court

may fully and fairly exercise its jurisdiction over the pending mandamus

petition. Without a stay, the Real Party may take actions—such as attempting

to enforce void orders or conduct discovery—that would create procedural

complications or moot portions of the mandamus before this Court can rule.

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Because the harm is ongoing, immediate, and cannot be corrected later,

Relator respectfully requests that the Court issue temporary relief without awaiting

a response, as permitted by TRAP 52.10(b). Given the imminent risk of irreparable

harm, Relator requests immediate temporary relief under TRAP 52.10(b). Should

the Court prefer to request a response, Relator defers to the Court’s discretion.

V. PRAYER

Relator respectfully requests that the Court grant this Motion for Emergency

Relief under TRAP 52.10 and:

1. Stay all orders issued by Judge Cory R. Liu in the underlying case;

2. Prohibit enforcement or reliance upon those orders pending mandamus

review;

3. Preserve the status quo by preventing GLO from compelling Relator’s

deposition or engaging in litigation activity based on void orders; and

4. Grant all further relief to which Relator is entitled.

Respectfully submitted,

/s/ Cedric M. Scott

Cedric M. Scott, PhD
Relator, Pro Se
Email: cedricscott41@gmail.com

Date: December 9, 2025

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CERTIFICATE OF SERVICE

I certify that a true and correct copy of the foregoing Relator’s Motion for

Emergency Relief was served in accordance with Texas Rule of Appellate

Procedure 9.5, on December 9, 2025 by electronic service (e-Filing) to the

following:

Real Party in Interest Counsel

Sara Labashosky
State Bar No. 24129467
slabashosky@bickerstaff.com

Gunnar P. Seaquist
State Bar No. 24043358
gseaquist@bickerstaff.com

Bickerstaff Heath Delgado Acosta LLP
3711 S. MoPac Expressway
Building One, Suite 300
Austin, Texas 78746
(512) 472-8021

Respondent
The Honorable Cory R. Liu
Judge of the 250th Judicial District Court
(Recused in Trial Court Cause No. D-1-GN-25-000006)
Travis County, Texas
Email: 250.Submission@traviscountytx.gov

/s/ Cedric M. Scott
Cedric M. Scott, PhD
Relator, Pro Se

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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: 108866059
Filing Code Description: Motion - Exempt
Filing Description: Relator's Motion for Emergency Relief
Status as of 12/9/2025 7:26 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Honorable Cory R.Liu 250.submission@traviscountytx.gov 12/9/2025 1:24:20 AM SENT

Jeffrey Moore jmoore@bickerstaff.com 12/9/2025 1:24:20 AM SENT

Sara Labashosky slabashosky@bickerstaff.com 12/9/2025 1:24:20 AM SENT

Gunnar Seaquist gseaquist@bickerstaff.com 12/9/2025 1:24:20 AM SENT