Main Practice Contacts

Lynne Liberato
+1 713.547.2017


Nina Cortell
+1 214.651.5579


Karen S. Precella
+1 817.347.6620

Related Services




Superseding and Enforcing Judgments

Protecting a client's assets during the appeal of a money judgment requires mastery of the technical rules that govern supersedeas bonds and stays of execution. Helping a client who has won a money judgment obtain a fair and expeditious outcome also calls for a special set of skills. Clients need skilled counsel to ensure the best result in each circumstance. Haynes and Boone's appellate lawyers provide the highest levels of counseling, strategy, and advocacy in these areas. Our areas of experience include the following:


  • Negotiating agreements with opposing parties to reduce the risk and expense of judgment enforcement;
  • Counseling clients regarding the costs and benefits of a full range of options for enforcing a judgment;
  • Preparing and filing supersedeas bonds to stay the enforcement of judgments;
  • Preparing motions to stay enforcement in federal courts;
  • Advocating for or challenging reduced supersedeas bonds in state and federal trial courts;
  • Persuading federal trial courts to follow the Texas statute that limits a supersedeas bond to 50 percent of the defendant’s net worth;
  • Staying the enforcement of a judgment requiring specific performance by an Oklahoma real estate developer, where it was impossible to procure a supersedeas bond;
  • Obtaining appellate review of trial court orders granting or denying a reduced supersedeas bond;
  • Providing strategy, advice, and advocacy in post-judgment hearings involving turnover, garnishment, sequestration, attachment, and related enforcement procedures; and
  • When necessary, coordinating efforts with bankruptcy counsel.