Case Information

*0 RECEIVED IN 5th COURT OF APPEALS DALLAS, TEXAS 3/25/2015 11:30:17 AM LISA MATZ Clerk *1 FILED DALLAS COUNTY 3/11/2015 1:26:05 PM FELICIA PITRE 05-15-00364-CV DISTRICT CLERK

CAUSE NO. DC-1407493

ABBIE GAIL BYRD § IN THE DISTRICT COURT

Plaintiff, §

V. § DALLAS COUNTY, TEXAS

JNH FOOD, LLC d/b/a PIZZA HUT; § 95 TH JUDICIAL DISTRICT COURT

Defendants. §

NOTICE OF APPEAL

This Notice of Appeal is filed by ABBIE GAIL BYRD, Plaintiff/Petitioner, a party to this

proceeding who seeks to alter the trial court’s jud gment or other appealable order.

1. The trial court, cause number, and style of this case are as shown in the caption

above.

2. ABBIE GAIL BYRD appeals to the Fifth District Court of Appeals.

3. The judgment or order appealed from was signed on Wednesday, November 12,

2014 in Cause No. DC-14-07493.

4. This case was severed from Cause No. DC-14-07439 on February 21, 2015.

5. ABBIE GAIL BYRD desires to appeal from the summary judgment ruling in

favor of JNH FOOD, LLC. More specifically, ABBIE GAIL BYRD desires to

appeal the trial court ’ s ruling regarding the controlling question of law as to

which there is a substantial ground for difference of opinion in that whether the

injury to Plaintiff occurred within the scope and/or course of her employment.

There is a substantial ground for difference of opinion based on the facts of this

case and the determination of this question of law will determine whether Plaintiff

has a cause of action against Defendant, JNH FOOD, LLC, or if Plaintiff is barred

by Worker’s Compensation from bringing this suit .

Respectfully submitted,

Nag & Scalise

1030 N. Davis Dr., Arlington TX 76012

T: (817) 900-2823 | F: (817) 585-4781

Notice of Appeal ^[1] *2 Jayson Nag

By: ____________________________________

Jayson Nag

Attorney for Petitioner, ABBIE GAIL BYRD

State Bar No.: 24075545

Email: jayson@arlingtontexaslegal.com

Certificate of Service

I certify that a true copy of this Notice of Appeal was served in accordance with the

Texas Rules of Civil Procedure on March 11, 2015. Jayson Nag

__________________________________

Jayson Nag

Attorney for Petitioner, ABBIE GAIL BYRD

Timothy U. Stanford

Downs & Stanford, P.C.

2001 Bryan Street, Suite 4000

Dallas, Texas 75201

Notice of Appeal ^[2]