CourtListener 10740949

Testo completo

ACCEPTED
15-25-00197-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
11/21/2025 12:49 PM
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 12:49:55 PM
DOMINIQUE REED AND DAKOTA HILL, Appellants
CHRISTOPHER A. PRINE
Clerk
v.
CYPRESS CREEK AT SOUTH CEDAR, Appellee
――――――――――――――――――――――――――――――――――――――――――――――――――

On Appeal from County Court at Law No. 1 of Bell County
Trial Court No. 25CCV01420
Hon. Paul A. Motz, Presiding
――――――――――――――――――――――――――――――――――――――――――――――――――

EMERGENCY NOTICE OF EXECUTION OF WRIT OF
POSSESSION AND EXTREME URGENCY

TO THE HONORABLE JUSTICES OF THE FIFTEENTH COURT OF APPEALS:

Appellants Dominique Reed and Dakota Hill file this EMERGENCY NOTICE to inform the

Court that the Writ of Possession is now actively being executed, with eviction scheduled for

tomorrow, November 22, 2025, at 11:20 AM.

I. IMMINENT IRREPARABLE HARM

1. Writ Executed: The FINAL WARNING OF EVICTION was posted on the premises

on November 21, 2025, at 11:20 AM, by the Bell County Sheriff's Office.

2. Harm is Irreversible: The imminent eviction will render Appellants homeless for the

second time in one year. This catastrophic harm, which includes the displacement of a

minor child, cannot be remedied by any subsequent legal or monetary judgment.
3. Judicial Causation: The current crisis is not due to Appellants' lack of funds or diligence.

The crisis is caused solely by the District Court’s failure to act on Appellants’ multiple

emergency motions to release the readily available Court Registry Funds $10,493.33

equity funds (Exhibit A) necessary to maintain the appellate stay and prevent this

irreparable life altering harm.

II. MANDATORY APPELLATE INTERVENTION

The District Court's failure to take the matter seriously constitutes an abuse of discretion that

directly caused the execution of the writ, forcing Appellants into homelessness.

Appellants have provided evidence demonstrating:

● Funds are sufficient and available (Exhibit A).

● Diligent attempts to access funds were made (Exhibit C).

● The District Court refused to rule timely (Exhibit F).

● The underlying eviction judgment is jurisdictionally void (Section II.( -C) of Emergency

Motion For Reconsideration Of November 19, 2025 Order And Motion To Reinstate

Appellate Stay Under Tex. R. App. P. 29.3 And 24.4(C) Motion).

Appellants pray that the Court will immediately review the concurrently filed Emergency Motion

for Reconsideration and use its equitable powers to issue an Order of Abatement and

reinstatement of the appellate stay to prevent the appeal from being rendered moot and to prevent

this irreparable harm.
Respectfully Submitted,

/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 EMERGENCY

NOTICE OF EXECUTION OF WRIT OF POSSESSION AND EXTREME URGENCY was

served via electronic filing upon all counsel of record for Appellee, CYPRESS CREEK AT

SOUTH CEDAR.

/s/ Dominique Reed

Dominique Reed, Pro Se

/s/ Dakota Hill

Dakota Hill, Pro
EXHIBIT (A) COVER SHEET

NO. 15-25-00197-CV
IN THE FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
DOMINIQUE REED AND DAKOTA HILL, Appellants

CYPRESS CREEK AT SOUTH CEDAR, Appellee

APPELLANTS’ EXHIBIT A

A WRIT OF POSSESSION HAS BEEN ISSUED FOR YOU TO VACATE THE
PREMISES.
THIS WRIT MAY BE EXECUTED AT ANY TIME ON OR AFTER THE SPECIFIED
DATE.
THIS IS YOUR FINAL WARNING TO VACATE THESE PREMISES
WITHIN 24 HOURS FROM THE DATE OF THIS NOTICE.
FAILURE TO VACATE THESE PREMISES WILL RESULT IN ALL PERSONAL
PROPERTY BEING REMOVED AND PLACED CURBSIDE.
THE REMOVAL OF YOUR PERSONAL PROPERTY WILL BE EFFECTED WITH OR
WITHOUT YOUR PRESENCE.

EXHIBIT (C) COVER SHEET

NO. 15-25-00197-CV
IN THE FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
DOMINIQUE REED AND DAKOTA HILL, Appellants

CYPRESS CREEK AT SOUTH CEDAR, Appellee

APPELLANTS’ EXHIBIT C

FILED SEPTEMBER 15, 2025- JUDGE DENIED MOTION

MOVANT DOMINIQUE REED'S EMERGENCY EX PARTE MOTION FOR
TEMPORARY RELIEF AND MOTION TO SEAL ADDRESS

FILED OCTOBER 24, 2025- NO RESPONSE FROM COURT AFTER EMAILS

EMERGENCY MOTION FOR PARTIAL DISTRIBUTION OF FUNDS FROM
RECEIVERSHIP ESTATE.

FILED NOVEMBER 17, 2025 - NO RESPONSE FROM COURT PRIOR TO
NOVEMBER 20, 2025

ORDER GRANTING SUBMISSION AND AUTHORIZING IMMEDIATE RULING ON
SUPPLEMENTAL EMERGENCY MOTION TO WITHDRAW PARTIAL FUNDS FROM
COURT REGISTRY

FILED NOVEMBER 19, 2025- NO RESPONSE FROM COURT PRIOR TO NOVEMBER
20, 2025

NOTICE OF ADVERSE APPELLATE RULING AND RENEWED REQUEST FOR
EMERGENCY ORDER INSTANTER
NO. 23DFAM337543

IN THE MATTER OF THE IN THE DISTRICT CQURT

MARRIAGE OF
146TH JUDICIAL

DOMINIQUE AC REED DISTRICT

AND BELL COUNTY, TEXAS

CARL LEE HILL

MOVANT DOMINIQUE REED'S EMERGENCY EX PARTE MOTION FOR

TEMPORARY RELIEF AND MOTION TO SEAL ADDRESS

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW, DOMINIQUE REED ("Movant"), representing herself pro se, and files this

Emergency Ex Parte Motion for Temporary Relief and Motion to Seal Address. In support,

Movant respectfully shows the Court the following:

I. INTRODUCTION

1. Movant seeks narrowly tailored, emergency ex parte relief to
prevent immediate and

irreparable harm. Movant and her daughter face imminent eviction and homelessness due

to an inability to post the required $897.00 appeal bond. These funds are available from

the proceeds of the sale of the marital residence, which are
currently held by a court-

appointed Receiver. Without an immediate order from this Court releasing these funds,

Movant will lose her right to appeal the eviction, resulting in
catastrophic harm for which
there is no adequate remedy at law.

Copy from re:SearchTX
2. Additionally, Movant, a participant in the Texas Address Confidentiality Program
(ACP),
seeks an immediate order to seal her
physical address, which was improperly disclosed in

public filings in the separate eviction proceeding. Given the history of
family violence in
this case, this disclosure presents an immediate and
ongoing threat to the safety of
Movant and her daughter.

Il. FACTUAL BACKGROUND

3. Movant and Respondent were married for 16 years. The
marriage was marked by family
violence and cruelty committed by Respondent. On December
16, 2022, Respondent

committed an act of family violence that resulted in criminal
charges. Respondent

ultimately entered a plea and received deferred adjudication for family violence on

November 8, 2024, with the case being dismissed on Februar 6, 2025.
y
4. The daughter of the marriage has chosen not to have contact with her
father, the

Respondent, since November of 2023, due to his emotional cruelty, and abusive behavior.

5. Respondent abandoned the marital residence. While Respondent continued to pay

household bills which also included a majority of his own
obligations he denied nearly

every additional request for support for Movant or their daughter, leaving them without

meaningful support and forcing them into financial instability. During the pendenc of
y
the divorce, Respondent engaged in a
pattern of coercive financial control, including

misrepresenting and concealing community assets such as a 401(k), investment account
s,
and a bank account titled in his sole name
opened during the marriage into which

community property paychecks were deposited.

6. Shortly after being summoned in his criminal family violence case, Respond
ent initiated
retaliatory civil proceedings against Movant, seeking the appoint
ment of a receiver to

Copy from re:SearchTX
force the sale of the marital home. This action was
designed to strip Movant of her

remaining equity and leave her without the financial means to secure housing.

7. The Court ordered Movant and her daughter to vacate the marital residence
by December
1, 2024, leaving them without stable housing ultimate
ly rendering them homeless for
over five months until Movant was able to secure
housing May 9", 2025. Shortly after
our daughter of the marriage graduate
d high school and court ordered child support ended

June, 2025 this left the Movant and daughter unable to fully stabilize
financially after

being homeless.

8. On August 15, 2025, the court-appointed Receiver
completed the sale of the marital

residence. The proceeds from that sale are
currently under the Receiver's control.

9. Movant and her 18-year-old daughter, who is listed as a tenant on their current
lease, now

face imminent eviction. To perfect an appeal of this eviction, Movant must
post a bond of

$897.00 with the Justice Court by September 15", 2025 by
5:00pm. Movant has no other

funds available to post this bond.

10. Movant and her daughter are participants in the Texas Address
Confidentiality Program
due to the history of family violence.
Despite this, their current physical address has been

publicly filed in the eviction case, creating a significant and immediate safety risk.

Hl. ARGUMENT AND AUTHORITIES

A. Emergency Release of Funds to Prevent Irreparab Harm
le

10. A court may grant temporary relief to preserve the status
quo and prevent irreparable
harm pending a final resolution. In re Newton, 146 S.W.3d
648, 651 (Tex. 2004).

Irreparable harm is an injury for which the injured party cannot be
adequately
compensated by damages. Here, the harm is clear: without an immediate order
releasing
the $897 for the appeal bond, Movant and her
daughter face homelessness. An eviction

Copy from re:SearchTX
on their record will create a severe, long-term barrier to
securing future housing. This is

not an injury that can be remedied by monetary
damages after the fact.

11. A court has the inherent authority to issue equitable relief to protect a
litigant's
fundamental right to appeal. In re Smith, 1 92 S.W.3d 564, 568
(Tex. 2006) (recognizing
a court's authority to protect a party's rights
pending appeal). The funds to prevent this
harm are available and under the control of the Court's
appointed Receiver. The relief

requested is narrowly tailored to release only the amount necessary to preserve Movant's

rights and prevent the immediate and irreparable harm of homelessness.

B. Sealing Address is Necessary for Safety

12. The public disclosure of the physical address of a survivor of
family violence constitutes
an immediate threat of irreparable harm. Movant and her
daughter are participants in the

Texas Address Confidentiality Program, which is designed to
protect them from such

risks.

13. Pursuant to the Texas Rules of Civil Procedure and Texas Government
Code, a court may
order filings sealed to prevent a specific, serious, and substantial interest which
clearly

outweighs any presumption of openness. Tex. R. Civ. P. 76a; Tex. Gov't Code § 58.052.

The physical safety of a party and her child, particula
rly in a case with a documented

history of family violence, is precisely the kind of interest these rules are meant to

protect. Movant requests that the Court seal all filings containing the Movants
physical
address and order that all ACP substitute address be used in all future
filings.

IV. REASONS JUSTIFYING EX PARTE RELIEF

14. This Motion is brought on an ex parte basis because Movant will suffer immedia
te and

irreparable injury before the adverse party can be heard in opposition. The deadline to

Copy from re:SearchTX
post the eviction appeal bond is imminent. Any delay will result in the loss of Movant's

right to appeal and will lead directly to homelessness for her and her daughter.

15. Furthermore, notice should not be required because of the history of retaliato
ry litigation
and coercive control exhibited by the Respond
ent. Providing notice of this specific

request for funds could prompt Respondent to take actions to obstruct or interfere with

the Receiver's ability to promptly comply with the Court's
order, thereby frustrating the

purpose of this emergency motion. Given the safety concerns, ex parte relief is also

necessary to allow the Court to seal Movant's address before Respondent has an

opportunity to further disseminate it.

V. PRAYER

WHEREFORE, PREMISES CONSIDERED, Movant Dominique Reed respectfully prays that
this Court immediately:

1. GRANT this Emergency Ex Parte Motion;
2. ORDER the court-appointed Receiver to immediately release $897.00 from the
proceeds
of the sale of the marital residence and direct those funds to the Justice Court 1 court

registry as to serve as the bond for Movant's eviction appeal deadline today Septemb
er
15", 2025 by 5:00pm.

3. ORDER the Bell County District Clerk to immediately seal all current and future
filings
that contain Movant's physical address and
replace it with her Address Confidentiality

Program (ACP) substitute address; and

4. GRANT Movant such other and further relief, at law or in equity, to which she
may be
justly entitled.

Respectfully Submitted,

Dominiaue AC Reed
Copy from re:SearchTXAD SE
Notice to Defendant of Requirements upon filing
Pauper's Affidavit

Cause #11CV2501103

To Dominique Reed, Dakota Hill, Defendant

Amount of Rent that must be paid into the Justice Court
Registry: $ 897.00
by the 15th day of September, 2025.
Rule 506.1(e), Texas Rules of Civil Procedure.

FAILURE TO PAY THE REQUIRED AMOUNT INTO THE JUSTICE COURT
REGISTRY BY THE DATE PRESCRIBED BY SUBDIVISION (3) MAY RESULT IN
THE COURT ISSUING A WRIT OF POSSESSION WITHOUT A HEARING.

(initial) I hereby acknowledge the receipt of my Notice to deposit rent into the
egistry/of the court.

(initial) I understand in the event that I fail to deposit the rent into the registry of the
cou rt that a Writ of Possession may bei SSueE

Date: 3 bAD Signa re:

"ry

Copy from re:SearchTX
Cause # 11CV2501103

Cypress Creek at South Cedar § IN THE JUSTICE COURT
Plaintiff

VS PRECINCT ONE
§

Dominque Reed, Dakota Hill
and all other occupants §
Defendant BELL COUNTY, TEXAS
FINAL JUDGMENT
This the 2nd day of September, 2025, being the appearance date of the Defendant,
Dominque
Reed, Dakota Hill, and the Court being regularly in session in term time at the place where the
above-styled and numbered cause was commenced, in which cause Cypress Creek at South Cedar
is Plaintiff, represented by attorney Doreen Wagner and Dominque Reed, Dakota Hill is
Defendant; and came the parties in person, and by attorney, and announced ready for trial; and
neither party having demanded jury. all matters in controversy of fact and of law were submitted
a

to the Court; and the pleadings, evidence and arguments of the
parties having been heard, the Court
finds that the Plaintiff, Cypress Creek at South Cedar, should have
possession of the premises
described in Plaintiff's petition, and the Court further finds that Plaintiff should recover for cost
and rent and assesses his damages therefore at $2,405.51.

IT, IS THEREFORE, ADJUDGED AND DECREED by the Court that the said Plaintiff,
Cypress Creek at South Cedar, have restitution of the said premises, for which let Writ of
Possession issue, to wit:

460 South Cedar Rd #11208 Temple. Tx. 76502

and further that Plaintiff do have and recover of and from said Defendant the sum of $2,226.51 as
rent, with interest thereon from date at the rate of 7.50 % per annum, attorney fees in the amount
of $0.00 and court cost in the amount of $179.00, for which let execution issue.
Appeals to be filed with the court on or before 8th day of September, 2025, Defendant's appeal
bond set at $3,481.51, with monthly rentals paid into the
registry of the County Court p the
appeal in the amount of $897.00 monthly
:

Signed this the 2nd day
in
:
«Theodore R. Duffield
of the Peace, Precinct
f Justice
Bell
: : County Texas
2

it you are an individual (not a com
4
ney or property may be protected from being taken to pay this judgment. Find
out more by visiting www..texaslaw help.g/exempt-
property / Si usted es una persona fisica (vy no una compafiia) su dinero 0
propiedad pudieran estar protegidos de ser embargados como pago de esta deuda decretada en juicio en contra suya,
Obtenga
mavor informacion visitando el sitio www.texaslawhelp.org/exempt-p
roperty.
You may appeal this judgment by filing a bond, making a cash deposit, or
filing a Statement of Inability to Afford
Payment of Court Costs within 5 days after this judgment was signed. See Texas Rule ofCivil Procedure 510.9(a).

Copy from re:SearchTX
FAMILY JUDGES DOCKET
Cause Number: 23DFAM337543 Type of Case: Divorce: Children

Style of Case Attorneys

Petitioner’s Attorney: GARY CUNHA
In the Matter of the Marriage of CARL LEE HILL and
DOMINIQUE REED Respondent’s Attorney: DOMINIQUE AC REED

Orders of Court

09/15/2025 Docket Entry

Court reviewed Emergency Motion for Temp Ex parte Relief. Court denies motion.

Page 1 of 1
23DFAM337543 In the Matter of the Marriage of CARL LEE HILL and DOMINIQUE REED 09/15/2025

Copy from re:SearchTX
Filed 10/24/2025 12:46 PM
Joanna Staton, District Clerk
District Court - Bell County, TX
by Melissa Wallace , Deputy

NO. 23DFAM337543

CARL LEE HILL § DISTRICT COURT
§
PLAINTIFF
§
§
v. § 146TH DISTRICT
§
§
DOMINIQUE A REED
§
DEFENDANT § BELL COUNTY, TEXAS

EMERGENCY MOTION FOR PARTIAL DISTRIBUTION OF FUNDS FROM

RECEIVERSHIP ESTATE.

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW, DOMINIQUE REED ("Movant"), acting Pro Se, and files this Emergency Motion

for Partial Distribution of Funds from the Receivership Estate, and in support thereof, would

respectfully show the Court as follows:

I. INTRODUCTION

1. Movant respectfully requests an emergency partial distribution of her equity funds currently

held by the court-appointed Receiver. This is Movant’s second request for such relief. The

Court considered and denied a prior motion on September 15, 2025, which was filed when an

eviction was a pending threat. The circumstances have now critically escalated. Movant has

exhausted all possible alternatives to secure the required cash bond. She lacks the personal

FWD CC SMW 10/24/25
assets or credit history required for traditional underwriting, and securing a surety bond is not

feasible as it requires 100% cash collateral, which she does not possess. The potential harm

that was previously a future risk has now ripened into a certain, imminent, and irreparable

injury that will occur today, October 24, 2025, without the Court’s immediate intervention.

2. Specifically, the County Court has ordered that a supersedeas bond/Cash Deposit be paid by

4:45 p.m. today to stay a writ of possession that will render Movant and her 18-year-old

daughter homeless. This motion is not a request to reconsider the prior ruling, but rather a

necessary plea based on a material and adverse change in circumstances that now presents a

clear case of irreparable harm. Movant has a vested interest in the funds held by the Receiver

and has no other means to prevent the guaranteed loss of her family's housing, personal

property, and transportation.

II. FACTUAL BACKGROUND

3. The court-appointed Receiver is in possession of proceeds from the sale of the marital

residence. These funds include Movant’s substantial equity interest and represent Movant's

sole financial resource after losing her job. Movant is recently unemployed and has no other

income or assets.

4. Movant currently lacks the funds for basic necessities, including food and utilities, further

compounding the emergency nature of this request.
5. Movant and her 18-year-old daughter, who is a named tenant on their apartment lease, face

immediate removal from their home. Following an adverse ruling in an eviction appeal in the

County Court at Law, Movant must deposit a cash deposit/check in lieu of a supersedeas

bond of $5,382.00 into the court’s registry to prevent the issuance of a writ of possession.

6. The absolute deadline for this payment is 4:45 p.m. on October 24, 2025. Failure to pay the

bond will result in the immediate issuance of the writ, leading to homelessness.

7. In addition to the bond, Movant is required to pay $897.00 into the court registry on or before

November 1, 2025, as a condition of maintaining the appeal, continuing each month on the

1st until the appeal mandate.

8. All of Movant’s personal property is located in storage units. The storage facility has

scheduled the contents for auction on November 6, 2025, due to non-payment. This property

includes all of her family’s furniture, clothing, and irreplaceable personal effects.

9. The property where Movant resides will not make exceptions to the tow policy and has begun

tagging Movant’s vehicles for towing due to expired registrations. The lack of a stable and

legal vehicle recently caused Movant to lose her job. This situation is compounded by the

fact that Movant’s ex-spouse, after numerous requests, has refused to provide his residential

address, which is necessary to effectuate the title transfers of the vehicles awarded to Movant

in the divorce. This non-compliance creates an additional barrier to legally owning and

operating the vehicles, causing further undue hardship. One vehicle was already towed
prematurely, before the date on the warning sticker, Movant was then required to arrange for

its pickup, causing further hardship. Without funds to renew the registration and the ability to

legally transfer title as ordered in the divorce, the loss of essential transportation is imminent.

III. ARGUMENT AND AUTHORITIES

For emergency relief to be granted, a movant must typically establish (1) a probable right to the

relief sought; (2) a probable, imminent, and irreparable injury in the interim; and (3) no adequate

remedy at law. See Butnaru v. Ford Motor Co., 84 S.W.3d 198, 204 (Tex. 2002). Movant meets this

standard.

A. Movant Will Suffer Imminent and Irreparable Injury.

10. An injury is irreparable if the injured party cannot be adequately compensated in damages or

if the damages cannot be measured by any certain pecuniary standard. Id. The harms facing

Movant are the very definition of irreparable.

11. Certain Homelessness: If the cash payment in lieu of the supersedeas bond is not posted by

4:45 p.m. today, Movant and her daughter will be forcibly removed from their home.

Homelessness is a profound and irreparable harm that a later award of money cannot cure.

12. Long-Term Barrier to Housing: The issuance of a writ of possession will create a formal

unlawful eviction judgment on the public records of both Movant and her 18-year-old
daughter. For a young adult, this judgment creates a severe, multi-year impediment to

securing future housing, a harm that transcends monetary value and prejudices her ability to

achieve independence.

13. Permanent Loss of Personal Property: The scheduled storage auction on November 6, 2025,

will result in the permanent loss of all the family's tangible property, including items of

sentimental value that are, by their nature, irreplaceable.

14. Loss of Essential Transportation: The imminent towing of Movant’s vehicles will cut off her

ability to seek employment, attend court proceedings, or manage essential family needs,

creating a cycle of crisis for which monetary damages are an inadequate remedy.

B. Movant Has a Probable Right to the Relief Sought.

15. The funds held by the Receiver are, in significant part, Movant’s own property, representing

her equity interest in the sold marital residence. While the final division of the receivership

estate is pending, her right to a substantial portion of these specific funds is not in dispute.

This motion does not ask the Court to award property, but merely to release a small portion

of Movant's own funds to prevent a manifest injustice. Denying access to these funds under

these extreme circumstances is contrary to the equitable purpose of a receivership, which is

to preserve the property and secure justice for the parties, not to be an instrument of

irreparable harm.
IV. CONCLUSION

Without the Court's immediate intervention, a series of irreversible and catastrophic events will

unfold, beginning this afternoon. The relief requested is not a final determination of rights but a

necessary advance against Movant's own funds to preserve the status quo and prevent a grave and

inequitable outcome.

V. PRAYER

WHEREFORE, PREMISES CONSIDERED, Movant DOMINIQUE REED respectfully prays that

the Court:

1. Grant an expedited hearing on this Motion due to the extreme and time-sensitive nature of the

matter;

2. Grant this Emergency Motion for Partial Distribution;

3. Sign an Order directing the Receiver, MARK MAHLER, to immediately distribute from the

receivership estate in the following sums:

4. $5,382.00 to be paid as a cash deposit or by check in lieu of a supersedeas bond to the

COUNTY COURT AT LAW 1 registry cause #25CCV01420 by 4:45pm today October

24, 2025;
5. $897.00 to be paid into the court registry cause #25CCV01420 for the November 1, 2025

rent deposit;

6. $694.00 to be paid to Dominique Reed to cure the default on Movant's storage units to stop

auction proceedings.

7. $134.00 to be paid to Dominique Reed to renew vehicle registrations of 2012 Jeep Wrangler

and 2015 Toyota Tundra.

8. $500.00 to be paid to Dominique Reed for essential living expenses, including food and

utilities.

9. Grant such other and further relief to which Movant may be justly entitled.

Respectfully submitted,

________________________________________

Dominique Reed, Pro Se Appellant

(Address Confidential – ACP Participant)

Email: Domir1974@gmail.com Phone: 512-763-2003
CERTIFICATE OF SERVICE

I hereby certify that on October 24, 2025, a true and correct copy of the foregoing Emergency

Motion was served in accordance with the Texas Rules of Civil Procedure on the court-appointed

Receiver, MARK MAHLER, and counsel for Plaintiff , GARY CUNHA, via state e-file system

DOMINIQUE REED
RightSpace Storage - 3076 - Belton
1709 Sparta Road
Belton , TX 76513
(254)312-2293

Duffy, Keira
2705 Mystic Mountain Lane
Belton, TX 76513

Unit Number: 145 Date: 10/02/2025

Notice of Lien Sale- Texas

Dear Keira Duffy,

Notice is hereby given that your rent is now thirty (30) days or more delinquent. To date,
you have failed to respond to our attempts to collect the balance owed. As provided in
your rental agreement you have been denied access to your storage space. The contents
of your leased space are subject to the facility's operator's lien.

Balance owed: As of the date of this notice, you owe RightSpace Storage - 3076 - Belton $311.00

Description of Personal Property Stored: Entire contents of unit consisting of, but not limited to:
air conditioner, motorcycle helmets, tow hitch, shredder, sofa, luggage, mattress, box spring, folding
table, baby items, boxes, totes, clothes, misc.

Unless full payment for all charges due are paid within fourteen (14) days, from the date of this notice,
the items stored in the Unit will be advertised for sale and the stored property will be sold or otherwise
disposed of at the following date, time and place:

Auction date and time: 11/06/2025, 10:00 AM. Your personal property
will be listed for public bidding on-line at www.storagetreasures.com beginning two weeks before the
Auction Date and Time which is when the highest bidder will be determined and the sale concluded.

Auction address: RightSpace Storage - 3076 - Belton 1709 Sparta Road Belton, TX 76513 This is the
Address where the sale will be concluded after all bids are received.

If no person purchases the personal property at the sale, the property may be sold at a private sale or
destroyed.
In order to prevent this from happening, payment IN FULL on your account by Cashier's Check, Money
Order or Credit Card must be received at RightSpace Storage - 3076 - Belton's address above before the
sale date and time. Rent and other charges will continue to accrue until paid in full.
If you or your spouse is in military service, please contact us concerning your current military status
immediately.

If you have any questions, you may contact the facility manager, as owner's agent, at the facility address
and phone number referenced above.

An itemized list of the amounts owed follows:

Charge Date Description Amount Tax Discount Payments/Allowance Balance

Rent Charged - 08/28/2025 to
08/28/2025 96.00 0.00 0.00 0.00 96.00
09/27/2025

Insurance - 08/28/2025 to
08/28/2025 12.00 0.00 0.00 0.00 12.00
09/27/2025

Late Fee: $20/20%- 5 Days -
09/03/2025 20.00 0.00 0.00 0.00 20.00
08/28/2025 to 09/27/2025

Rent Charged - 09/28/2025 to
09/28/2025 96.00 0.00 0.00 0.00 96.00
10/27/2025

Insurance - 09/28/2025 to
09/28/2025 12.00 0.00 0.00 0.00 12.00
10/27/2025

09/29/2025 Set Lien- Texas 75.00 0.00 0.00 0.00 75.00

Sincerely,

RightSpace Storage - 3076 - Belton
RightSpace Storage - 3076 - Belton
1709 Sparta Road
Belton , TX 76513
(254)312-2293

Duffy, Keira
2705 mystic mountain lane
Belton, TX 76513

Unit Number: 160 Date: 10/02/2025

Notice of Lien Sale- Texas

Dear Keira Duffy,

Balance owed: As of the date of this notice, you owe RightSpace Storage - 3076 - Belton $255.00

Description of Personal Property Stored: Entire contents of unit consisting of, but not limited to:
boxes, totes, end table, clothes, TV, vanity mirror, decor, misc.

Auction address: RightSpace Storage - 3076 - Belton 1709 Sparta Road Belton, TX 76513 This is the
Address where the sale will be concluded after all bids are received.

If you have any questions, you may contact the facility manager, as owner's agent, at the facility address
and phone number referenced above.

An itemized list of the amounts owed follows:

Charge Date Description Amount Tax Discount Payments/Allowance Balance

Rent Charged - 08/07/2025 to
08/07/2025 58.00 0.00 0.00 0.00 58.00
09/06/2025

Insurance - 08/07/2025 to
08/07/2025 12.00 0.00 0.00 0.00 12.00
09/06/2025

Late Fee: $20/20%- 5 Days -
08/13/2025 20.00 0.00 0.00 0.00 20.00
08/07/2025 to 09/06/2025

Rent Charged - 09/07/2025 to
09/07/2025 58.00 0.00 0.00 0.00 58.00
10/06/2025

Insurance - 09/07/2025 to
09/07/2025 12.00 0.00 0.00 0.00 12.00
10/06/2025

09/10/2025 Set Lien- Texas 75.00 0.00 0.00 0.00 75.00

Late Fee: $20/20%- 5 Days -
09/13/2025 20.00 0.00 0.00 0.00 20.00
09/07/2025 to 10/06/2025

Sincerely,

RightSpace Storage - 3076 - Belton
RightSpace Storage - 3076 - Belton
1709 Sparta Road
Belton, TX 76513
(254)312-2293

Keira Duffy
2705 Mystic Mountain Lane
Belton, TX 76513

MONTHLY INVOICE

IMPORTANT INFORMATION
Please pay on or before the Payment Due Date below. You can pay by (1) credit card, (2) check, (3) cashier's
check, (4) money order or (5) sign into the NSA Storage Customer Portal at
https://nsabrands-payment.ssm-erp.com/
Please note we no longer accept cash payments.
Questions about your Invoice? Please call your RightSpace Storage - 3076 - Belton Manager at (254)312-2293.

Invoice Number: 251021050356374

Unit # Charge Date Description Amount Tax Discount Total

New Dues
Rent Charged - 10/28/2025 to
145 10/28/2025 $96.00 $0.00 $0.00 $96.00
11/27/2025

145 10/28/2025 Insurance - 10/28/2025 to 11/27/2025 $12.00 $0.00 $0.00 $12.00

Other Dues
Rent Charged - 08/28/2025 to
145 08/28/2025 $96.00 $0.00 $0.00 $96.00
09/27/2025

145 08/28/2025 Insurance - 08/28/2025 to 09/27/2025 $12.00 $0.00 $0.00 $12.00

Late Fee: $20/20%- 5 Days -
145 09/03/2025 $20.00 $0.00 $0.00 $20.00
08/28/2025 to 09/27/2025

Rent Charged - 09/28/2025 to
145 09/28/2025 $96.00 $0.00 $0.00 $96.00
10/27/2025

145 09/28/2025 Insurance - 09/28/2025 to 10/27/2025 $12.00 $0.00 $0.00 $12.00

145 09/29/2025 Set Lien- Texas $75.00 $0.00 $0.00 $75.00
Late Fee: $20/20%- 5 Days -
145 10/04/2025 $20.00 $0.00 $0.00 $20.00
09/28/2025 to 10/27/2025

Notice Date: 10/21/2025 Payment Due Date: Total Amount Due :
10/28/2025 Total Due $439.00
Prepaid Rent/Fee $0.00
Balance Due $439.00

Have you moved? Contact the office or sign into the NSA Storage Customer Portal at
https://nsabrands-payment.ssm-erp.com/

Thank you for renting from RightSpace Storage - 3076 - Belton
CAUSE NO. 25CCV01420

§ IN THE COUNTY COURT
§
VS. § AT LAW #1

DEFENDANT § BELL COUNTY, TEXAS

FINAL JUDGMENT

On this day, came to be heard the above-entitled and numbered cause. Plaintiff,
appeared by and through their attorney and announced "ready". Defendant, DOMINIQUE REED, DAKOTA
HILL AND ALL OCCUPANTS, although duly noticed did not appear/appeared pro-se and announced "ready".
No jury having been demanded; the entire matter was submitted to the Court. After hearing and considering of the
pleadings and evidence, the Court finds that DOMINIQUE REED, DAKOTA HILL ANDAL CUPANTS are
justly indebted to for back rent in the amount of $
attorney fees, along with the court costs in the amount of $179.00, plus post-judgment interest at the rate df 7.50% per
annum until judgment is paid in full.

The Court also finds is entitled to possession of the property located at:

IT IS THEREFORE ORDERED, ADJUDGED, AND DECREED that CYPRESS CREEK AT SOUTH CEDAR
have and recover of and from said DOMIN QUE REED, DAKOTA HILL AND ALL OCCUPANTS the sum of
$3,125. for back rent, $ attorney fees, along with court costs in the amount of $179.00, plus post
judgment interest at the rate of 7.50% per annum until judgment is paid in full.

IT IS FURTHER ORDERED that the said have restitution of the said
premises by midnight on October 24", 2025, for which let Writ of Possession issue, to wit: property located at:

A PARTY AFFECTED BY THIS ORDER HAS THE RIGHT TO APPEAL TO THE THIRD COURT OF
APPEALS, AUSTIN, TEXAS.
If the appeal is taken, monthly rent to be paid into the Registry of the Court in the amount of $897.00 on the first day of
the month. If the monthly rent is not paid, Writ of Possession may issue without further hearing.

Also, a Supersedeas Bond in the amount of $5,382.00 must be filed by 4:45 pm on October 24", 2025, in the County
Clerk's office located at 1201 Huey Rd, Belton, TX 76513 to stay a pending judgm

SIGNED THIS 14TH DAY OF OCTOBER, 2025.

FILED FOR RECORD Judgd Présiding

OCT 15 2°
SHELLEY cer"
COUNTY CLK.
pe.
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: 107262183
Filing Code Description: Motion - No Fee
Filing Description: EMERGENCY MOTION FOR PARTIAL
DISTRIBUTION OF FUNDS FROM RECEIVERSHIP ESTATE PH SAW
Status as of 10/27/2025 1:23 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Dominique Reed Dominique.AC.Reed@outlook.com 10/24/2025 12:46:03 PM SENT

Service Only service@llslaw.com 10/24/2025 12:46:03 PM SENT

Gary Cunha gary@llslaw.com 10/24/2025 12:46:03 PM SENT

Mark Mahler mark@themahlergroup.com 10/24/2025 12:46:03 PM SENT

Shirley Smith litigation@templelawoffice.com 10/24/2025 12:46:03 PM SENT
Filing Submitted
Envelope Number: 108138371
Case Number: 23DFAM337543
Case Style: In the Matter of the Marriage of
CARL LEE HILL and DOMINIQUE REED

The filing below has been submitted to the clerk's office for review. Please allow 24 - 48 hours
for clerk office processing.

Filing Details
Court Bell County - District Clerk
Date/Time Submitted 11/17/2025 3:58 PM CST
Filing Type Motion - No Fee
SUPPLEMENTAL EMERGENCY MOTION FOR PARTIAL
Filing Description WITHDRAWAL OF FUNDS FROM COURT REGISTRY
(SUPPLEMENTING MOTION FILED OCTOBER 24, 2025)
Type of Filing EFileAndServe
Filed By Dominique Reed
Filing Attorney

Fee Details

Your account is never charged until your filing is accepted. If you see any pending charges on
your account prior to acceptance, this is an authorization hold to ensure the funds are
available so your filing can be accepted without delay.

If the filing is canceled or rejected these funds will be released and will return to your account
according to your financial institution's policies (typically 3-10 business days).

This envelope is pending review and fees may change.
Case Fee Information $0.00
Motion - No Fee $0.00
Total:$0.00 (The envelope still has pending filings and the fees are subject to change)
Document Details
Lead Document FINAL.pdf
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Filed 11/19/2025 10:32 AM
Joanna Staton, District Clerk
District Court - Bell County, TX
by MaryBeth DeLeon , Deputy

NO. 23DFAM337543

CARL LEE HILL § DISTRICT COURT
§
PLAINTIFF
§
§
v. § 146TH DISTRICT
§
§
DOMINIQUE A REED
§
DEFENDANT § BELL COUNTY, TEXAS

SUPPLEMENTAL EMERGENCY MOTION FOR PARTIAL WITHDRAWAL OF FUNDS

FROM COURT REGISTRY (SUPPLEMENTING MOTION FILED OCTOBER 24, 2025)

TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW DOMINIQUE A. REED, Pro

Se, and files this Supplemental Emergency Motion for Partial Withdrawal of Funds from the Court

Registry, supplementing her original Emergency Motion filed October 24, 2025, which remains

pending without hearing or ruling. Movant respectfully shows the Court as follows:

I. INTRODUCTION & PROCEDURAL HISTORY

1. Movant filed an Emergency Motion on October 24, 2025, requesting immediate release of a

portion of the equity awarded to her in the Final Decree of Divorce signed May 28, 2024. These

funds are currently held in the Bell County District Court Registry following the receiver’s sale of

the marital residence on August 15, 2025. Upon deposit of the sale proceeds into the District Court

Registry, the Receiver was formally discharged in this cause.

2. Movant has made repeated, documented attempts to obtain a hearing date or ruling, including

FWD TO CC 11.20.25 MW
emails to the Court Coordinator on October 24, October 28, and November 13, 2025, and calls to the

District Clerk’s Office on November 3, 6, and 10, 2025. Despite these efforts, Movant has not been

successful in securing a setting. As a self‑represented party, Movant faces added difficulty navigating

procedure but has acted diligently to comply with the Court’s requirements.

3. The Bell County District Clerk confirmed that $8,410.00 is currently on deposit in the Court

Registry and available for disbursement upon further orders of the court.

4. Movant files this Supplemental Emergency Motion due to the urgent risk of losing appellate

jurisdiction, housing, and significant property.

II. FACTUAL BACKGROUND

1. The marital residence was sold under a court appointed Receiver. The Order Approving Sale

signed August 15, 2025 required proceeds to be deposited into the District Court Registry.

2. Movant was awarded one half of the net equity. The amount requested of $8,410.00 has been

verified as available by the District Court Clerk.

3. Funds are needed for: $5,382 supersedeas deposit; $1,794 rent registry payment for months

November and December; $600 storage/truck; $134 registration for vehicles; $500 essentials

food/utilities.

4. Movant relocated property under an amnesty agreement involving the storage account. Additional

storage is required. “Movant has already incurred moving expenses, as shown by the U‑Haul receipt

(Exhibit P). Despite renting one storage unit, the space was insufficient to hold all property. The

requested withdrawal amount of $8,410.00 includes funds necessary to secure additional storage to
prevent the loss of essential belongings awarded in the Divorce Decree.”

5. Movant has no savings, credit, or alternative funds.

III. APPELLATE JURISDICTION AT RISK (SEPARATE CIVIL CASE):

This Motion relates to a separate civil appeal pending in the Fifteenth Court of Appeals, where

Movant and her daughter Dakota Hill are co-appellants in an eviction matter. A temporary stay was

issued by the appeals court on October 29th, 2025, However on November 10, 2025, Appellee filed

a Motion to Dissolve the Stay, claiming Movant failed to make required deposits and arguing that

Movant does not have the funds to pay the supersedeas bond and court registry rent. This claim is

directly contradicted by the verified availability of $8,410.00 in equity funds accessible to Movant

from the balance currently held in the registry of this District Court under Cause No.

23DFAM337543.

Although the Plaintiff in the pending Court of Appeals matter disputes Movant’s position and alleges

that she is stalling or lacks funds, the record demonstrates that Movant’s inability to make the

required payments arises solely from her lack of access to the equity awarded in the Final Decree of

Divorce dated May 28, 2025. Those funds remain in the District Court Registry following the

receiver’s discharge, and cannot be withdrawn without an order of this Court. Movant has made

diligent efforts to obtain release of the funds, including filing an Emergency Motion on September

15, 2025, which was denied. Movant is not refusing to pay; she is legally barred from doing so

absent Court authorization. Without immediate relief, dissolution of the appellate stay will result in

loss of possession of Movant’s home, rendering the appeal moot and causing irreparable harm. Once

possession is lost and stability is destroyed, no monetary award or subsequent remedy can restore the

home, cure the appeal, or undo the consequences of eviction and displacement. The harm is
immediate, ongoing, and incapable of being adequately compensated after the fact.

IV. LEGAL STANDARD (THREE-PRONG TEST)

Movant meets all elements:

1. Probable right: Funds awarded and available.

2. Irreparable harm: Loss of possession is irreparable harm.

3. No adequate remedy: Only this Court can release funds.

V. RESPONDENT’S MISREPRESENTATIONS & UNCLEAN HANDS (RESERVED):

Movant asserts that Respondent engaged in material misrepresentations and conduct amounting to

unclean hands, which directly contributed to the wrongful diminution of Movant’s awarded equity.

These actions include the use of false statements, misleading exhibits, and strategic abuse of process

designed to strip Movant of her rightful property division. While Movant reserves all rights to pursue

sanctions, restitution, and other relief in a separate motion, she places the Court on notice that

Respondent’s misconduct has already caused substantial harm to her equity interest and continues to

prejudice her ability to secure stability.

VI. RESERVATION OF RIGHTS:

Movant’s acceptance of funds pursuant to this Motion shall not constitute a waiver of any right or

claim regarding the receivership, sale, or distribution of property. Movant expressly preserves the

right to:

1. Obtain a complete receivership accounting;

2. Challenge any fees, costs, or expenses previously disbursed;

3. Challenge compliance with the Final Decree of Divorce;
4. Challenge material misrepresentations made in connection with these proceedings;

5. Assert claims based on unclean hands or other equitable defenses;

6. Seek restitution, surcharge, disgorgement, or sanctions as appropriate;

7. File future motions addressing irregularities, inequities, or other improper conduct.

VII. PRAYER FOR RELIEF:

Movant respectfully prays that the Court:

1. Grant this Emergency Supplemental Motion in full instanter; because dissolution of the

appellate stay will result in immediate loss of possession of Movant’s home, rendering the

appeal moot and causing irreparable harm. Such harm cannot be cured by monetary damages

or subsequent relief, and only immediate withdrawal of funds paid into the trial court registry

will preserve Movant’s statutory right to appeal and prevent homelessness.

2. Order the immediate release of $8,410.00 from the District Court Registry to Movant for the

express purpose of curing statutory deficiencies and preventing irreparable harm;

3. Enter findings supporting the necessity of emergency relief to preserve Movant’s rights and

stability;

4. Acknowledge and incorporate the District Clerk’s verification of available funds into the

Court’s Order;

5. Grant Movant leave to file a separate Motion for Surcharge, Restitution, and Sanctions

against the Receiver for loss of equity resulting from the Receiver’s unauthorized sale of the

marital residence in direct violation of the Final Decree of Divorce and Texas Family Code

§ 9.007;
6. Grant Movant leave to file a separate Motion for Sanctions, Restitution, and Relief

against Respondent Carl Hill and third parties acting in concert with him based on their

Fraud on the Court and the submission of false sworn affidavits on material facts in

initiating the receivership, which caused undue hardship and diminution of Movant’s

awarded equity;

7. Grant Movant such other and further relief, general and special, at law and in equity, to which

she may be justly entitled.

Respectfully submitted,

/s/ Dominique A. Reed

Participant, Address Confidentiality Program

Email: domir1974@gmail.com

Phone: 512-763-2003

CERTIFICATE OF SERVICE I hereby certify that on November 17, 2025, a true and correct
copy of this SUPPLEMENTAL EMERGENCY MOTION FOR PARTIAL WITHDRAWAL OF
FUNDS FROM COURT REGISTRY was served via the Texas e‑File system upon Gary Cunha,
attorney of record for Respondent Carl Hill, in Cause No. 23DFAM337543.

Respectfully submitted,

/s/ Dominique Reed, Pro Se
EXHIBIT INDEX

EXHIBIT LIST

● Exhibit A – Emergency Motion filed October 24, 2025
● Exhibit B – Motion to Dissolve Stay (Appellee filing, November 10, 2025)
● Exhibit C – Final Judgment, Trial Court (October 15, 2025)
● Exhibit D – Divorce Decree (May 28, 2024)
● Exhibit E – Order Approving Sale and Discharging Receiver
● Exhibit F – Declaration of Clerk Balance Confirmation (November 12, 2025)
● Exhibit G – Amnesty Agreement and Declaration Regarding Storage Units
● Exhibit H – Photograph of Temporary Vehicle Tags (showing need for renewal)
● Exhibit I – Denial of Emergency Motion for Temporary Relief (September 15, 2025)
● Exhibit J – Email to Court Coordinator (October 24, 2025)
● Exhibit K – Follow‑up Email to Court Coordinator (October 28, 2025)
● Exhibit N – Follow‑up Email to Court Coordinator (November 13, 2025)
● Exhibit O – Declaration of Calls to District Clerk’s Office (November 3, 6, and 10,
2025)
● Exhibit P – U‑Haul Receipt and Declaration (November 2025)
● Exhibit Q – Rental Receipt for New Storage Unit and Declaration (November 2025)
Filed 10/24/2025 12:46 PM
Joanna Staton, District Clerk
District Court - Bell County, TX
EXHIBIT A by Melissa Wallace , Deputy

NO. 23DFAM337543

CARL LEE HILL § DISTRICT COURT
§
PLAINTIFF
§
§
v. § 146TH DISTRICT
§
§
DOMINIQUE A REED
§
DEFENDANT § BELL COUNTY, TEXAS

EMERGENCY MOTION FOR PARTIAL DISTRIBUTION OF FUNDS FROM

RECEIVERSHIP ESTATE.

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW, DOMINIQUE REED ("Movant"), acting Pro Se, and files this Emergency Motion

for Partial Distribution of Funds from the Receivership Estate, and in support thereof, would

respectfully show the Court as follows:

I. INTRODUCTION

1. Movant respectfully requests an emergency partial distribution of her equity funds currently

held by the court-appointed Receiver. This is Movant’s second request for such relief. The

Court considered and denied a prior motion on September 15, 2025, which was filed when an

eviction was a pending threat. The circumstances have now critically escalated. Movant has

exhausted all possible alternatives to secure the required cash bond. She lacks the personal

FWD CC SMW 10/24/25
EXHIBIT A

assets or credit history required for traditional underwriting, and securing a surety bond is not