Preview
Electronically Filed
10/13/2023 2:42 PM
Hidalgo County District Clerks
Reviewed By: Valerie Moreno
CAUSE NO. C-3517-23-E
SYLVIA ESPNOZA, § IN THE DISTRICT COURT
Plaintiff §
§
VS. §
§
THE CITY OF PHARR, § 275TH JUDICIAL DISTRICT
AND §
PHARR-SAN JUAN-ALAMO §
INDEPENDENT SCHOOL DISTRICT, §
AND §
XAVIER SANCHEZ, INDIVIDUALLY, §
Defendants § HIDALGO COUNTY, TEXAS
DEFENDANT CITY OF PHARR’S PLEA TO THE JURISDICTION
_______________________________________________________________
MAY IT PLEASE THE COURT:
COMES NOW DEFENDANT CITY OF PHARR TEXAS (hereinafter “City”), and file
this Plea to the Jurisdiction, requesting that the Court dismiss the claims against them for lack of
jurisdiction, in whole or in part, based on any one or more of the reasons set forth below.
I. NATURE OF THE CASE/FACTUAL BACKGROUND
This is a premise liability negligence action presently brought against the City of Pharr, a
municipality/governmental entity organized under the laws of the State of Texas and brought
against Pharr-San Juan-Alamo Independent School District (“PSJA”). Plaintiff’s claims arise from
personal injuries sustained by Plaintiff when she allegedly fell on an unmarked and incomplete
curb sidewalk at the UTRGV Natatorium located at 3001 North Cage Blvd, in Hidalgo Couty,
Texas on January 29, 2022. See Plaintiff’s Original Petition.
II. EXHIBITS IN SUPPORT OF PLEA TO THE JURISDICTION
Ex. A. Lease and Joint Use and Management Agreement between City of Pharr and PSJA
III. SUMMARY OF THE ARGUMENT
The court lacks jurisdiction over the claims against the Defendants because the Defendant
City is immune from the claims brought by Plaintiff and such immunity has not been waived
pursuant to the Texas Tort Claims Act (hereafter “TTCA” or “Tort Claims Act”). The Plaintiff
cannot show that the Defendant has waived its governmental immunity as to the negligence
Defendants’ Plea to the Jurisdiction Page 1
Electronically Filed
10/13/2023 2:42 PM
Hidalgo County District Clerks
Reviewed By: Valerie Moreno
premise liability claims against it as the duty to manage, operate, and make necessary repairs to
the premises were assumed by PSJA by a lease agreement between the City of Pharr and PSJA.
IV. STANDARD OF REVIEW
Subject matter jurisdiction cannot be presumed and cannot be waived. See Continental
Coffee Prds. Co. v. Casarez, 937 S.W.2d 444, 448-49 n. 2 (Tex. 1996). A plea to the jurisdiction
is proper to challenge a suit brought against a governmental entity when it is apparent from the
pleadings on file that the claims asserted are not within any waiver of sovereign immunity. See
Tex. Dept. Of Transportation v. Jones, S.W.3d 636, 637-39 (Tex. 2000); see also Texas Parks &
Wildlife Dept. vs. Garrett Place Inc., 972 S.W.2d 140 (Tex. App. - Dallas 1998). Plaintiff bears
the burden of alleging facts affirmatively showing the trial court it has subject matter jurisdiction
over the Defendant(s). See Texas Ass’n of Business v. Texas Air Control Bd., 852 S.W.2d 440
(Tex. 1993).
For government entities, sovereign/governmental immunity has two component parts -
immunity from suit and immunity from liability. A party suing a governmental entity must allege
consent to suit either by reference to statute or express legislative permission. See Garrett Place,
Inc., 972 S.W.2d at 143 citing Missouri Pac. R.R. v. Brownsville Navigation Dist., 453 S.W.2d
812, 813 (Tex. 1970). In the absence of a pleading or consent, the trial court has no jurisdiction to
hear the case. See Brownsville Navigation Dist., 453 S.W.2d at 814; see also Ntreh v. Univ. Of
Tex. at Dallas, 936 S.W.2d 649, 651 (Tex. 1997). If a governmental entity is sued without
legislative consent, the trial court should grant the governmental entity’s plea to the jurisdiction,
unless the Plaintiff can affirmatively demonstrate that its claim fits within one or more provisions
of the waiver of immunity provided for in the Texas Tort Claims Act. See Garrett Place Inc., 972
S.W.2d at 143.
A court deciding a plea to the jurisdiction is not required to look solely to the pleadings but
may consider evidence and must do so when necessary to resolve the jurisdictional issues raised.
Bland Independent School Dist. v. Blue, 34 S.W.3d 547, 555 (Tex. 2000). Additionally, a court is
to look at the allegations in the petition and accept those allegations as true, unless the defendant
establishes that either: (1) that the plaintiff's pleadings, taken as true, affirmatively establish that
the trial court lacks subject matter jurisdiction over the suit; or, (2) that the plaintiff pled
fraudulently or in bad faith with the purpose of conferring jurisdiction, where under the true facts
Defendants’ Plea to the Jurisdiction Page 2
Electronically Filed
10/13/2023 2:42 PM
Hidalgo County District Clerks
Reviewed By: Valerie Moreno
of the case the trial court would not have jurisdiction. Denton County v. Howard, 22 S.W.3d 113,
117-18 (Tex. App.-Fort Worth 2000).
V. ARGUMENT AND AUTHORITIES
A. The Defendant is a Governmental Entity for Purposes of Immunity
The Defendant City of Pharr hereby requests that the Court take judicial notice that it is a
municipality organized under the laws of the State of Texas for purposes of immunity and the
application of the Tort Claims Act. Tex. Civ. Prac. & Rem. Code §101.001. The City has properly
raised in its Answer, its entitlement to sovereign and governmental immunity through affirmative
defenses.
B. TTCA Waivers of Immunity to Premises Defect and The City delegated the duty to
maintain and repair sidewalks to Property Owners pursuant to City Ordinance.
A party suing a governmental entity must allege consent to suit either by reference to statute
or express legislative permission. Texas Parks & Wildlife Dept. vs. Garrett Place Inc., 972 S.W.2d
140, 143 (Tex. App. - Dallas, 1998) citing Missouri Pac. R.R. v. Brownsville Navigation Dist., 453
S.W.2d 812, 813 (Tex. 1970). Immunity from suit completely bars an action against the
governmental entity unless the entity waives its immunity and consents to suit. Austin ISD v.
Gutierrez, 54 S.W.3d 860, 862 no.3 (Tex.App.-Austin 2001, no pet.). The waiver of governmental
immunity is a matter addressed to the Texas Legislature. Univ. of Tex. Med. Branch at Galveston
v. Hohman, 6 S.W.3d 767, 775 (Tex.App.-Houston [1st Dist.] 1999, pet. dism'd w.o.j.) (citing City
of LaPorte v. Barfield, 898 S.W.2d 288, 291 (Tex.1995)).
In the Tort Claims Act, the Legislature has laid out a scheme for a limited waiver of
governmental immunity. See Tex. Civ. Prac. & Rem. Code Ann. §101.001 et. seq. (Emphasis
Added.) In her Petition, the Plaintiff asserts the basis on which the City’s immunity has been
waived. under The Tort Claims Act Section pursuant to the Tort Claims Act Section 101.022
allows for a limited waiver of immunity for premises defect claims 1, and based on her assertion
that a unmarked and incomplete curb constituted a premises defect and dangerous condition.
Plaintiff’s Original Petition.
1
Tex. Civ. Prac. & Rem. Code Ann. §101.001 et seq.
Defendants’ Plea to the Jurisdiction Page 3
Electronically Filed
10/13/2023 2:42 PM
Hidalgo County District Clerks
Reviewed By: Valerie Moreno
(1) The City delegated the duty to maintain, operate and repair the premises to PSJA
pursuant to a 20-year lease entered between the parties.
The duty to make the premises safe or warn of dangerous conditions “generally runs with
the ownership or control of the property,” and a defendant's liability under a premises liability
theory rest on the defendant's assumption of control of the premises and responsibility for
dangerous conditions on it. Occidental Chemical Corp. v Jenkins, 478 S.W.3d 640, 644 (Tex.
2016); see Graham Cent. Station, Inc. v. Peña, 442 S.W.3d 261, 265 (Tex. 2014) (per curiam)
(noting that a premises liability plaintiff must prove the defendant's ownership or control). The
City of Pharr unambiguously delegated the responsibility of installation, maintenance, and repair
of the premises in this suit, including sidewalks, to PSJA during the twenty-year term of the lease
agreement. Ex. A ¶ 5.1(c). In addition to the shifting the responsibility of maintenance and repair
of the premises to PSJA, the parties agreed that the City shall not be liable to any person for injury
or damage to person or property. Id. at ¶ 2.3.
Case law is clear that these duties to maintain and repair the premises are delegable by
agreement. City of Austin v. Quinlan, 669 S.W.3d 813, 821-822 (Tex. 2023) (City of Austin was
found not liable for premises defect where, by ordinance, the City established a permit program
for sidewalk cafes allowing the delegation of the maintenance and repair of sidewalks according
to a contractual agreement with permit holders). Here, Plaintiff’s fall occurred on an unmarked
and incomplete curb at UTRGV Natatorium. Plaintiff’s Original Petition. As per the above-
mentioned Lease Agreement, the duty to maintain, operate, and repair the premises was delegated
to PSJA. See Ex. A. As such Plaintiff cannot plead any jurisdictional facts to show the City of
Pharr is liable for premises defects of located at the UTRGV Natatorium located at 3001 North
Cage Blvd., Hidalgo County, Texas.
CONCLUSION
Therefore, based on any one or more of the foregoing reasons, the City Defendants request
and pray that this Court find that the Plaintiff’s claims against the Defendants be DISMISSED as
a matter of law for lack of jurisdiction. The Defendants also pray for any relief to which it may
show itself justly entitled.
SIGNED this 13th day of October 2023.
Respectfully Submitted,
Defendants’ Plea to the Jurisdiction Page 4
Electronically Filed
10/13/2023 2:42 PM
Hidalgo County District Clerks
Reviewed By: Valerie Moreno
DENTON NAVARRO ROCHA
BERNAL & ZECH
A Professional Corporation
701 E. Harrison, Ste. 100
Harlingen, Texas 78550
956/421-4904
956/421-3621 (Fax)
By: Joshua Duane H. Neece
RICARDO J. NAVARRO
State Bar No. 14829100
rjnavarro@rampagelaw.com
JOSHUA DUANE H. NEECE
State Bar No. 24116819
jdhneece@rampagelaw.com
COUNSEL FOR DEFENDANTS
CITY OF PHARR
Defendants’ Plea to the Jurisdiction Page 5
Electronically Filed
10/13/2023 2:42 PM
Hidalgo County District Clerks
Reviewed By: Valerie Moreno
CERTIFICATE OF SERVICE
I certify that a true and correct copy of this document has been served on the persons or
parties identified below in accordance with one or more of the recognized methods of service by
the Texas Rules of Civil Procedure on the 13th day of October 2023.
Aaron Allison By E-Filing Methods
AARON ALLISON LAW FIRM
1601 Rio Grande, Ste. 520
Austin, Texas 78701
Email: genereal@aaronallisonlawfirm.com
Counsel for Plaintiff
Alejandro Martinez
Alex Martinez Law Office
421 S. 12th Street
McAllen, Texas 78501
Counsel for Plaintiff
David Campbell
Johan Holter
Benjamin Castillo
Alyssa Aleman
808 West Ave.
Austin, Texas 78701
Email: dcampbell@808west.com ; jholter@808west.com;
bcastillo@808west.com ; aaleman@808west.com
Joshua Duane H. Neece
RICARDO J. NAVARRO
JOSHUA DUANE H. NEECE
Defendants’ Plea to the Jurisdiction Page 6
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.
Aaron Gonzales on behalf of Joshua Neece
Bar No. 24116819
amgonzales@rampagelaw.com
Envelope ID: 80582381
Filing Code Description: Plea to the Jurisdiction
Filing Description: Defendant City of Pharr's Plea to the Jurisdiction
Status as of 10/16/2023 9:06 AM CST
Associated Case Party: Xavier Sanchez
Name BarNumber Email TimestampSubmitted Status
Aaron FeltonAllison general@aaronallisonlawfirm.com 10/13/2023 2:42:46 PM SENT
Associated Case Party: THE CITY OF PHARR
Name BarNumber Email TimestampSubmitted Status
Ricardo JNavarro rjnavarro@rampagelaw.com 10/13/2023 2:42:46 PM SENT
Joshua Duane H. Neece jdhneece@rampagelaw.com 10/13/2023 2:42:46 PM SENT
Aaron M.Gonzales amgonzales@rampagelaw.com 10/13/2023 2:42:46 PM SENT
Norma Delgado ngdelgado@rampagelaw.com 10/13/2023 2:42:46 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
David Campbell dcampbell@808west.com 10/13/2023 2:42:46 PM SENT
Ben Castillo bcastillo@808west.com 10/13/2023 2:42:46 PM SENT
Johan Holter jholter@808west.com 10/13/2023 2:42:46 PM SENT
Alyssa Aleman aaleman@808west.com 10/13/2023 2:42:46 PM SENT
Kathryn French kfrench@808west.com 10/13/2023 2:42:46 PM SENT
Preview
Electronically Filed 10/13/2023 2:42 PM Hidalgo County District Clerks Reviewed By: Valerie Moreno CAUSE NO. C-3517-23-E SYLVIA ESPNOZA, § IN THE DISTRICT COURT Plaintiff § § VS. § § THE CITY OF PHARR, § 275TH JUDICIAL DISTRICT AND § PHARR-SAN JUAN-ALAMO § INDEPENDENT SCHOOL DISTRICT, § AND § XAVIER SANCHEZ, INDIVIDUALLY, § Defendants § HIDALGO COUNTY, TEXAS DEFENDANT CITY OF PHARR’S PLEA TO THE JURISDICTION _______________________________________________________________ MAY IT PLEASE THE COURT: COMES NOW DEFENDANT CITY OF PHARR TEXAS (hereinafter “City”), and file this Plea to the Jurisdiction, requesting that the Court dismiss the claims against them for lack of jurisdiction, in whole or in part, based on any one or more of the reasons set forth below. I. NATURE OF THE CASE/FACTUAL BACKGROUND This is a premise liability negligence action presently brought against the City of Pharr, a municipality/governmental entity organized under the laws of the State of Texas and brought against Pharr-San Juan-Alamo Independent School District (“PSJA”). Plaintiff’s claims arise from personal injuries sustained by Plaintiff when she allegedly fell on an unmarked and incomplete curb sidewalk at the UTRGV Natatorium located at 3001 North Cage Blvd, in Hidalgo Couty, Texas on January 29, 2022. See Plaintiff’s Original Petition. II. EXHIBITS IN SUPPORT OF PLEA TO THE JURISDICTION Ex. A. Lease and Joint Use and Management Agreement between City of Pharr and PSJA III. SUMMARY OF THE ARGUMENT The court lacks jurisdiction over the claims against the Defendants because the Defendant City is immune from the claims brought by Plaintiff and such immunity has not been waived pursuant to the Texas Tort Claims Act (hereafter “TTCA” or “Tort Claims Act”). The Plaintiff cannot show that the Defendant has waived its governmental immunity as to the negligence Defendants’ Plea to the Jurisdiction Page 1 Electronically Filed 10/13/2023 2:42 PM Hidalgo County District Clerks Reviewed By: Valerie Moreno premise liability claims against it as the duty to manage, operate, and make necessary repairs to the premises were assumed by PSJA by a lease agreement between the City of Pharr and PSJA. IV. STANDARD OF REVIEW Subject matter jurisdiction cannot be presumed and cannot be waived. See Continental Coffee Prds. Co. v. Casarez, 937 S.W.2d 444, 448-49 n. 2 (Tex. 1996). A plea to the jurisdiction is proper to challenge a suit brought against a governmental entity when it is apparent from the pleadings on file that the claims asserted are not within any waiver of sovereign immunity. See Tex. Dept. Of Transportation v. Jones, S.W.3d 636, 637-39 (Tex. 2000); see also Texas Parks & Wildlife Dept. vs. Garrett Place Inc., 972 S.W.2d 140 (Tex. App. - Dallas 1998). Plaintiff bears the burden of alleging facts affirmatively showing the trial court it has subject matter jurisdiction over the Defendant(s). See Texas Ass’n of Business v. Texas Air Control Bd., 852 S.W.2d 440 (Tex. 1993). For government entities, sovereign/governmental immunity has two component parts - immunity from suit and immunity from liability. A party suing a governmental entity must allege consent to suit either by reference to statute or express legislative permission. See Garrett Place, Inc., 972 S.W.2d at 143 citing Missouri Pac. R.R. v. Brownsville Navigation Dist., 453 S.W.2d 812, 813 (Tex. 1970). In the absence of a pleading or consent, the trial court has no jurisdiction to hear the case. See Brownsville Navigation Dist., 453 S.W.2d at 814; see also Ntreh v. Univ. Of Tex. at Dallas, 936 S.W.2d 649, 651 (Tex. 1997). If a governmental entity is sued without legislative consent, the trial court should grant the governmental entity’s plea to the jurisdiction, unless the Plaintiff can affirmatively demonstrate that its claim fits within one or more provisions of the waiver of immunity provided for in the Texas Tort Claims Act. See Garrett Place Inc., 972 S.W.2d at 143. A court deciding a plea to the jurisdiction is not required to look solely to the pleadings but may consider evidence and must do so when necessary to resolve the jurisdictional issues raised. Bland Independent School Dist. v. Blue, 34 S.W.3d 547, 555 (Tex. 2000). Additionally, a court is to look at the allegations in the petition and accept those allegations as true, unless the defendant establishes that either: (1) that the plaintiff's pleadings, taken as true, affirmatively establish that the trial court lacks subject matter jurisdiction over the suit; or, (2) that the plaintiff pled fraudulently or in bad faith with the purpose of conferring jurisdiction, where under the true facts Defendants’ Plea to the Jurisdiction Page 2 Electronically Filed 10/13/2023 2:42 PM Hidalgo County District Clerks Reviewed By: Valerie Moreno of the case the trial court would not have jurisdiction. Denton County v. Howard, 22 S.W.3d 113, 117-18 (Tex. App.-Fort Worth 2000). V. ARGUMENT AND AUTHORITIES A. The Defendant is a Governmental Entity for Purposes of Immunity The Defendant City of Pharr hereby requests that the Court take judicial notice that it is a municipality organized under the laws of the State of Texas for purposes of immunity and the application of the Tort Claims Act. Tex. Civ. Prac. & Rem. Code §101.001. The City has properly raised in its Answer, its entitlement to sovereign and governmental immunity through affirmative defenses. B. TTCA Waivers of Immunity to Premises Defect and The City delegated the duty to maintain and repair sidewalks to Property Owners pursuant to City Ordinance. A party suing a governmental entity must allege consent to suit either by reference to statute or express legislative permission. Texas Parks & Wildlife Dept. vs. Garrett Place Inc., 972 S.W.2d 140, 143 (Tex. App. - Dallas, 1998) citing Missouri Pac. R.R. v. Brownsville Navigation Dist., 453 S.W.2d 812, 813 (Tex. 1970). Immunity from suit completely bars an action against the governmental entity unless the entity waives its immunity and consents to suit. Austin ISD v. Gutierrez, 54 S.W.3d 860, 862 no.3 (Tex.App.-Austin 2001, no pet.). The waiver of governmental immunity is a matter addressed to the Texas Legislature. Univ. of Tex. Med. Branch at Galveston v. Hohman, 6 S.W.3d 767, 775 (Tex.App.-Houston [1st Dist.] 1999, pet. dism'd w.o.j.) (citing City of LaPorte v. Barfield, 898 S.W.2d 288, 291 (Tex.1995)). In the Tort Claims Act, the Legislature has laid out a scheme for a limited waiver of governmental immunity. See Tex. Civ. Prac. & Rem. Code Ann. §101.001 et. seq. (Emphasis Added.) In her Petition, the Plaintiff asserts the basis on which the City’s immunity has been waived. under The Tort Claims Act Section pursuant to the Tort Claims Act Section 101.022 allows for a limited waiver of immunity for premises defect claims 1, and based on her assertion that a unmarked and incomplete curb constituted a premises defect and dangerous condition. Plaintiff’s Original Petition. 1 Tex. Civ. Prac. & Rem. Code Ann. §101.001 et seq. Defendants’ Plea to the Jurisdiction Page 3 Electronically Filed 10/13/2023 2:42 PM Hidalgo County District Clerks Reviewed By: Valerie Moreno (1) The City delegated the duty to maintain, operate and repair the premises to PSJA pursuant to a 20-year lease entered between the parties. The duty to make the premises safe or warn of dangerous conditions “generally runs with the ownership or control of the property,” and a defendant's liability under a premises liability theory rest on the defendant's assumption of control of the premises and responsibility for dangerous conditions on it. Occidental Chemical Corp. v Jenkins, 478 S.W.3d 640, 644 (Tex. 2016); see Graham Cent. Station, Inc. v. Peña, 442 S.W.3d 261, 265 (Tex. 2014) (per curiam) (noting that a premises liability plaintiff must prove the defendant's ownership or control). The City of Pharr unambiguously delegated the responsibility of installation, maintenance, and repair of the premises in this suit, including sidewalks, to PSJA during the twenty-year term of the lease agreement. Ex. A ¶ 5.1(c). In addition to the shifting the responsibility of maintenance and repair of the premises to PSJA, the parties agreed that the City shall not be liable to any person for injury or damage to person or property. Id. at ¶ 2.3. Case law is clear that these duties to maintain and repair the premises are delegable by agreement. City of Austin v. Quinlan, 669 S.W.3d 813, 821-822 (Tex. 2023) (City of Austin was found not liable for premises defect where, by ordinance, the City established a permit program for sidewalk cafes allowing the delegation of the maintenance and repair of sidewalks according to a contractual agreement with permit holders). Here, Plaintiff’s fall occurred on an unmarked and incomplete curb at UTRGV Natatorium. Plaintiff’s Original Petition. As per the above- mentioned Lease Agreement, the duty to maintain, operate, and repair the premises was delegated to PSJA. See Ex. A. As such Plaintiff cannot plead any jurisdictional facts to show the City of Pharr is liable for premises defects of located at the UTRGV Natatorium located at 3001 North Cage Blvd., Hidalgo County, Texas. CONCLUSION Therefore, based on any one or more of the foregoing reasons, the City Defendants request and pray that this Court find that the Plaintiff’s claims against the Defendants be DISMISSED as a matter of law for lack of jurisdiction. The Defendants also pray for any relief to which it may show itself justly entitled. SIGNED this 13th day of October 2023. Respectfully Submitted, Defendants’ Plea to the Jurisdiction Page 4 Electronically Filed 10/13/2023 2:42 PM Hidalgo County District Clerks Reviewed By: Valerie Moreno DENTON NAVARRO ROCHA BERNAL & ZECH A Professional Corporation 701 E. Harrison, Ste. 100 Harlingen, Texas 78550 956/421-4904 956/421-3621 (Fax) By: Joshua Duane H. Neece RICARDO J. NAVARRO State Bar No. 14829100 rjnavarro@rampagelaw.com JOSHUA DUANE H. NEECE State Bar No. 24116819 jdhneece@rampagelaw.com COUNSEL FOR DEFENDANTS CITY OF PHARR Defendants’ Plea to the Jurisdiction Page 5 Electronically Filed 10/13/2023 2:42 PM Hidalgo County District Clerks Reviewed By: Valerie Moreno CERTIFICATE OF SERVICE I certify that a true and correct copy of this document has been served on the persons or parties identified below in accordance with one or more of the recognized methods of service by the Texas Rules of Civil Procedure on the 13th day of October 2023. Aaron Allison By E-Filing Methods AARON ALLISON LAW FIRM 1601 Rio Grande, Ste. 520 Austin, Texas 78701 Email: genereal@aaronallisonlawfirm.com Counsel for Plaintiff Alejandro Martinez Alex Martinez Law Office 421 S. 12th Street McAllen, Texas 78501 Counsel for Plaintiff David Campbell Johan Holter Benjamin Castillo Alyssa Aleman 808 West Ave. Austin, Texas 78701 Email: dcampbell@808west.com ; jholter@808west.com; bcastillo@808west.com ; aaleman@808west.com Joshua Duane H. Neece RICARDO J. NAVARRO JOSHUA DUANE H. NEECE Defendants’ Plea to the Jurisdiction Page 6 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. Aaron Gonzales on behalf of Joshua Neece Bar No. 24116819 amgonzales@rampagelaw.com Envelope ID: 80582381 Filing Code Description: Plea to the Jurisdiction Filing Description: Defendant City of Pharr's Plea to the Jurisdiction Status as of 10/16/2023 9:06 AM CST Associated Case Party: Xavier Sanchez Name BarNumber Email TimestampSubmitted Status Aaron FeltonAllison general@aaronallisonlawfirm.com 10/13/2023 2:42:46 PM SENT Associated Case Party: THE CITY OF PHARR Name BarNumber Email TimestampSubmitted Status Ricardo JNavarro rjnavarro@rampagelaw.com 10/13/2023 2:42:46 PM SENT Joshua Duane H. Neece jdhneece@rampagelaw.com 10/13/2023 2:42:46 PM SENT Aaron M.Gonzales amgonzales@rampagelaw.com 10/13/2023 2:42:46 PM SENT Norma Delgado ngdelgado@rampagelaw.com 10/13/2023 2:42:46 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status David Campbell dcampbell@808west.com 10/13/2023 2:42:46 PM SENT Ben Castillo bcastillo@808west.com 10/13/2023 2:42:46 PM SENT Johan Holter jholter@808west.com 10/13/2023 2:42:46 PM SENT Alyssa Aleman aaleman@808west.com 10/13/2023 2:42:46 PM SENT Kathryn French kfrench@808west.com 10/13/2023 2:42:46 PM SENT