CAUSE NO.

2014-CI-07249
VALERIE REDUS, INDIVIDUALLY,
AND ROBERT M. REDUS,
INDIVIDUALLY, AND AS
ADMINISTRATOR OF THE ESTATE
OF ROBERT CAMERON REDUS,
PLAINTIFFS,

VS.

UNIVERSITY OF THE INCARNATE WORD

AND CHRISTOPHER J. CARTER,

DEFENDANTS.

IN THE DISTRICT COURT

OF BEXAR COUNTY, TEXAS

150TH JUDICIAL DISTRICT

DEFENDANT UNIVERSITY OF THE INCARNATE WORDS

NOTICE OF APPEAL
1.

Defendant UNIVERSITY OF THE INCARNATE WORD (UIW) files this

Notice of Appeal, pursuant to Rules 25.1(a), 26.1(b) and 28.1(b) of the Texas Rules of Appellate
Procedure, and Section 51.014(a)(8) of the Texas Civil Practice and Remedies Code, to appeal
the Order denying UIWs Plea to the Jurisdiction and Motion to Dismiss the suit against
Defendant Officer Cpl. Christopher Carter (Cpl. Carter) that was signed by the Honorable
Cathleen Stryker on March 3, 2015 (Order), in Cause No. 2014-CI-07249; Valerie Redus,
Individually, and Robert M. Redus, Individually, and as Administrator of the Estate of Robert
Cameron Redus v. University of the Incarnate Word and Christopher Carter; In the 150th
Judicial District Court of Bexar County, Texas.
2.

Defendant UIW desires to appeal said March 3, 2015 Order to the Fourth Court of

Appeals at San Antonio, Texas, which has jurisdiction over appeals from the district courts of
Bexar County, Texas. This is an accelerated appeal under Texas Rule of Appellate Procedure
28.1(a).

UNIVERSITY OF THE INCARNATE WORDS

NOTICE OF APPEAL

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3.

Defendant UIW will serve the Clerk of the San Antonio Court of Appeals with a

copy of this Notice of Appeal in accordance with Rule 25.1(e) of the Texas Rules of Appellate
Procedure.
4.

This matter has been on file in the state district court for less than 180 days after

the date Defendant filed its Original Answer in accordance with Texas Civil Practice and
Remedies Code 51.014(c)(2)(A)1.
Respectfully submitted,
BEIRNE, MAYNARD & PARSONS, L.L.P.
The Weston Centre
112 East Pecan Street, Suite 2750
San Antonio, TX 78205
(210) 582-0220 - Telephone
210) 582-0231 Facsimile
By:

/s/ Laurence S. Kurth

Laurence S. Kurth
State Bar No. 11768450
E-mail lkurth@bmpllp.com
Matthew F. Wymer
State Bar No. 24005234
E-mail mwymer@bmpllp.com

ATTORNEYS FOR DEFENDANT THE

UNIVERSITY OF THE INCARNATE WORD

Defendants Original Answer was filed on June 2, 2014. Notice of Removal was filed on June 5, 2014. Order remanding this matter to
state court was entered on November 25, 2014. Accordingly, this matter has been pending in the state district court a total of 100 days.

UNIVERSITY OF THE INCARNATE WORDS

NOTICE OF APPEAL

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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been forwarded to the
following counsel of record in accordance with the Texas Rules of Civil Procedure this 3rd
day of March, 2015:
Brent C. Perry
Law Office of Brent C. Perry, PC
800 Commerce Street
Houston, TX 77002
brentperry@brentperrylaw.com
Mason W. Herring
Herring Law Firm
4640 Banning Drive
Houston, TX 77027
mherring@herringlawfirm.com
Jorge Herrera
Herrera Law Firm
111 Soledad, Suite 1900
San Antonio, TX 78205
jherrera@herreralaw.com
Robert A. Valadez
Javier T. Duran
Shelton & Valadez
600 Navarro Street, Suite 500
San Antonio, TX 78205
rvaladez@shelton-valadez.com
jduran@shelton-valadez.com
/s/Laurence S. Kurth
Laurence S. Kurth

UNIVERSITY OF THE INCARNATE WORDS

NOTICE OF APPEAL

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