Case Information

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COURT OF APPEALS
FOURTH DISTRICT
CADENA-REEVES JUSTICE CENTER
SAN ANTONIO, TEXAS 78205- 3037

MARCUS EVERETTE HARPER, Plaintiff/Appellant. v.

TEXAS DEPARTMENT OF CRIMINAL JUSTICE, et, al, Defendants.

ADDENDUM MOTION FOR
INTERLOCUTORY APPEAL DOCKETING STATEMENT

TO THE HONORABLE JUDGE OF THIS COURT:

COMES now MARCUS E.HARPER herafter preferred to as Plainliff/ Appellant hereby move to proceed under docketing statement TEX.R. APP.P. 32 .

On 23 day of August 2015 Appellant filed his docketing statement but left out the claim for relief.

CLAIMS FOR RELIEF

1) Plaintiff ask that this honorable Court appoint counsel and allow immediate discovery in this (what will be) an extremely difficultmedical medical nealijence/malpractice and gross negligence safety violations cause 2) Plaintiff asks for jury trial to present his claims for full and equitable relief under T.T.C.A. $\$101$ and medical liability's (see also $\$33.013$ ) 3) Plaintiff seeks compensatory damages against each defendat both jointly and severally for his past, present, and future-pain suffering mental anguish and for the permanent scaring and disfigurement done to his body. 4) Plaintiff seeks punitive damages against ech defendant both jointly and severally to prevent defendant from allowing these types of grossly negligent safety violations to continue to injure and disfigure inmates in their charge in the future. 5) Plaintiff seeks legal fees and compensation for his time and effort in having to prsecute this cause of action due to prison officials malice and vindictiveness and unwillingness to resolve this claim. 6) Plaintiff seeks any additional relief which this Honorable Court or the jury deem just proper and equitable.

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*3 I Marcus Everette Harper # 692332, being presently incarcerated in Bill Clements Unit does hereby declare that all of the foregoing is true and correct to the best of knwledge and recolecion under penaly of perjury ( 28 U.S.C. $\$1749$ ) On 30 day of August 2015 sworn executed.

Marcus Everette Harper ${}^{\#692332}$ Bill Clements Unit 9601 Spur 591 Amarillo 'Ex 79107

*4 Clerk of the Court Court of Arepals Fourth District Cadima-Reeves Justice Center San Antonio, TX 78205-3037 Date: 8-30-2015 Court of Arepals no: 04-15-00489-CV Trial Court case no: 47, 305-C

Could you bring this motion emoddendam to intertocunory docketina Statement to the Honorable Judae of this court and file thank You.

Marus Haper 4602332 Marellis Harper Bill Clemmits Unit 4601 6Pur 541 Amarillo, TX 74127

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