Dominique Reed and Dakota Hill v. Cypress Creek at South Cedar

ACCEPTED
15-25-00197-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
11/21/2025 10:30 AM
IN THE FIFTEENTH COURT OF APPEALSCHRISTOPHER A. PRINE
CLERK
FILED IN
15th COURT OF APPEALS
NO. 15-25-00197-CV AUSTIN, TEXAS
11/21/2025 10:30:01 AM
DOMINIQUE REED AND DAKOTA HILL, Appellants
CHRISTOPHER A. PRINE
Clerk
v.
CYPRESS CREEK AT SOUTH CEDAR, Appellee
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On Appeal from County Court at Law No. 1 of Bell County
Trial Court No. 25CCV01420
Hon. Paul A. Motz, Presiding
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NOTICE OF FILING OF PARTIAL EXHIBITS AND INTENT TO SUPPLEMENT

TO THE HONORABLE JUSTICES OF THE FIFTEENTH COURT OF APPEALS:

Appellants Dominique Reed and Dakota Hill file this Notice to inform the Court that the

attached Emergency Motion for Reconsideration is being filed with only the two most critical

and time-sensitive exhibits (Exhibit A and Exhibit F).

Pursuant to Texas Rule of Appellate Procedure 10.2 (governing emergency relief), Appellants

have prioritized the immediate submission of the core Motion, Exhibit A (Proof of Funds), and

Exhibit F (Proof of Judicial Obstruction/Imminent Harm) to enable the Court to instantly

reissue the stay and halt the execution of the Writ of Possession.

These exhibits are necessary for the Court to determine the immediate need for an Order of

Abatement and temporary orders under TRAP 24.4(c).
Appellants certify that they will file the remaining Supplemental Exhibits (B, B-1, C, D, D-1,

E, G, H, I) Appellant’s exhibits will be completed and submitted within the next few hours, no

later than 12:00 p.m. today, November 21, 2025, to ensure the appellate record is fully

complete. Appellant’s respectfully prays for immediate review.

Respectfully Submitted,

/s/ Dominique Reed

Dominique Reed, Pro Se

/s/ Dakota Hill Dakota Hill, Pro Se
CERTIFICATE OF CONFERENCE

I certify that I conferred with opposing counsel on November 21, 2025 regarding the subject
matter of this motion as required by Texas Rule of Appellate Procedure 10.1(a)(5). At this time,
Appellants have received no response from opposing counsel regarding their position on this
Emergency Motion.

/s/ Dominique Reed

Dominique Reed, Pro Se

/s/ Dakota Hill

Dakota Hill, Pro Se

CERTIFICATE OF SERVICE

I hereby certify that on November 21, 2025, a true and correct copy of this motion was served
via electronic filing upon all counsel of record for Appellee, CYPRESS CREEK AT SOUTH
CEDAR, including Joshua Anderson and Richard Alexander Barclay, at their email addresses
listed in the Appellee's filing.

/s/ Dominique Reed

Dominique Reed, Pro Se

/s/ Dakota Hill

Dakota Hill, Pro ​ ​ ​
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: 108326552
Filing Code Description: Motion - Exempt
Filing Description: NOTICE OF FILING OF PARTIAL EXHIBITS AND
INTENT TO SUPPLEMENT
Status as of 11/21/2025 10:54 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Brooke Broderick broderick@hooverslovacek.com 11/21/2025 10:30:01 AM SENT

Alex Barclay barclay@hooverslovacek.com 11/21/2025 10:30:01 AM SENT

Dominique ACReed dominique.ac.reed@outlook.com 11/21/2025 10:30:01 AM SENT

Joshua Anderson janderson@hooverslovacek.com 11/21/2025 10:30:01 AM ERROR