On April 17, 2009 a
Motion-Secondary
was filed
involving a dispute between
Adle, John J,
Allen, Richard F,
Anderson, Laura K,
Anderson, Tommy W,
Bailey, Thomas C Iii,
Barksdale, Janet M,
Barnes, Douglas H,
Foster, Bruce H,
Gross, Pamela Sue,
Mack, Don G,
Owens, James D,
Peacock, Marilyn,
Peacock, Scott,
and
Appraisal Review Board Of Harris County Appraisal District,
Harris County Appraisal District,
for APPEAL APPRAISAL BOARD
in the District Court of Harris County.
Preview
9.9
NO. 2009-24300
BRUCE H. FOSTER. § IN THE DISTRICT COURT OF
et al §
§
VS § HARRIS COUNTY, TEXAS
HARRIS COUNTY APPRAISAL FILED
Loren Jackson
DISTRICT, et al. § 152"? JUDICIAL: DISTRICT
PLAINTIFFS’ OBJECTION TO THE DEFENDANT’S pean 1 5.
TO THE JURISDICTION Time “ A
~_. -
Come now the Plaintiff, PAMELA SUE GROSS, and file this objection tothe Defendant's
Plea to the Jurisdiction. For response, Plaintiffs would show the following
The Plaintiffs object to the affidavits attached to and used as affirmative evidence supporting
the Defendant's Plea. The Affidavit of Jim Robinson, HCAD Chief Appraiser, is hearsay without an
exception thereto and from an interested party, therefore it is inadmissible as evidence. Additionally,
the Defendant has failed to list Mr. Robinson in any Disclosures as a person with knowledge of
relevant facts and is therefore inadmissible. The Affidavit of Peggy Seddon, HCAD Director of
Human Resources, is hearsay without an exception thereto and from an interested party, therefore it
is inadmissible as evidence. Additionally, the Defendant has failed to list Ms. Seddon in any
Disclosures as a person with knowledge of relevant facts and is therefore inadmissible
WHEREFORE, PREMISES CONSIDERED, Plaintiffs pray the Court in all things sustain
Plaintiffs’ Objection to Defendant’s Plea to the Jurisdiction and for such other relicf as is
appropriate.
RESPECTFUPLY SUBMITTED,
aU H ¥. MCKENNEY
SBOT#13706100
2200North Loop West, Suite 333
Ho&ston, Texas 77018
(713) 688-6767
(713) 688-0199 telefax
CERTIFICATE OF SERVICE
I certify that a copy of the above document was delivered to:
James Robinson Tammy White-Chaffer
G. Todd Stewart _____ Kenneth Wall
Robert McConnell Sara Sundrla
Sarah Morrow Mario Dell’Osso
Olson & Olson
2727 Allen Parkway, Suite 600
Houston, Texas 77019
(713) 533-3888 Facsimile
L. Susan Herrera _ Michael Gary
Ryan Miller
Harris County Appraisal District
Office of General Counsel
13013 NW Freeway, 7th Floor
Houston, Texas 77040
P.O.Box 920975
Houston, Texas 77292
(713) 957-5219 Facsimile
on the l 5 day of aan_-2010, via facsimile transmission.
Hugh L. McKenney
Document Filed Date
January 19, 2010
Case Filing Date
April 17, 2009
Category
APPEAL APPRAISAL BOARD
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9.9 NO. 2009-24300 BRUCE H. FOSTER. § IN THE DISTRICT COURT OF et al § § VS § HARRIS COUNTY, TEXAS HARRIS COUNTY APPRAISAL FILED Loren Jackson DISTRICT, et al. § 152"? JUDICIAL: DISTRICT PLAINTIFFS’ OBJECTION TO THE DEFENDANT’S pean 1 5. TO THE JURISDICTION Time “ A ~_. - Come now the Plaintiff, PAMELA SUE GROSS, and file this objection tothe Defendant's Plea to the Jurisdiction. For response, Plaintiffs would show the following The Plaintiffs object to the affidavits attached to and used as affirmative evidence supporting the Defendant's Plea. The Affidavit of Jim Robinson, HCAD Chief Appraiser, is hearsay without an exception thereto and from an interested party, therefore it is inadmissible as evidence. Additionally, the Defendant has failed to list Mr. Robinson in any Disclosures as a person with knowledge of relevant facts and is therefore inadmissible. The Affidavit of Peggy Seddon, HCAD Director of Human Resources, is hearsay without an exception thereto and from an interested party, therefore it is inadmissible as evidence. Additionally, the Defendant has failed to list Ms. Seddon in any Disclosures as a person with knowledge of relevant facts and is therefore inadmissible WHEREFORE, PREMISES CONSIDERED, Plaintiffs pray the Court in all things sustain Plaintiffs’ Objection to Defendant’s Plea to the Jurisdiction and for such other relicf as is appropriate. RESPECTFUPLY SUBMITTED, aU H ¥. MCKENNEY SBOT#13706100 2200North Loop West, Suite 333 Ho&ston, Texas 77018 (713) 688-6767 (713) 688-0199 telefax CERTIFICATE OF SERVICE I certify that a copy of the above document was delivered to: James Robinson Tammy White-Chaffer G. Todd Stewart _____ Kenneth Wall Robert McConnell Sara Sundrla Sarah Morrow Mario Dell’Osso Olson & Olson 2727 Allen Parkway, Suite 600 Houston, Texas 77019 (713) 533-3888 Facsimile L. Susan Herrera _ Michael Gary Ryan Miller Harris County Appraisal District Office of General Counsel 13013 NW Freeway, 7th Floor Houston, Texas 77040 P.O.Box 920975 Houston, Texas 77292 (713) 957-5219 Facsimile on the l 5 day of aan_-2010, via facsimile transmission. Hugh L. McKenney