Preview
Cause No.2016-49450
HEMANT GAJARAWALA, Individually § IN THE DISTRICT COURT OF
§
Plaintiff, §
§
DEVSJ CONCRETE, LLC, derivatively on behalf §
Of Texas Concrete Enterprise IV, LLC § HARRIS COUNTY, TEXAS
Intervenor Plaintiff §
§
vs. §
§
SOMAIAH KURRE §
§
Defendant § 80 JUDICIAL DISTRICT
PLAINTIFFAND INTERVENOR PLAINTIFF’S
RESPONSE IN OPPOSITION TO DEFENDANT SOMAIAH KURRE’S MOTION FOR
JUDGMENT NOTWITHSTANDING THE VERDICT
Plaintiff Hemant Gajarawala (“Mr. Gajarawala”), and Plaintiff Intervenor DEVSJ
Concrete, LLC (“DEVSJ”) submit this Response to Def ndant Somaiah Kurre’s Motion for
Judgment Notwithstanding the Verdict and states as follows:
Background
jury verdict in this case was rendered n favor of Pla tiff and DEVSJ and
against Defendant Somaiah Kurre (“Defendant”) February 23 after 4 days of evidence
was presented via various witnesses and trial exhibits tendered by the parties
The unanimous verdict was adopted by the Court.
By their verdict, the jury found that:
(A) Mr. Gajarawala and Kurre agreed that, if Mr. Gajarawala personally guaranteed
two loans from Allegiance Bank to Texas Concrete Enterprise, then Mr. Kurre would
work to ensure that the Kendleton Cement Plant would be operational and profitable in a
timely manner;
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Mr. Kurre failed to comply with the agreement that, if Mr. Gajarawala personally
guaranteed two loans from Allegiance Bank to Texas Concrete Enterprise, then Mr.
Kurre would work to ensure that the Kendleton Cement Plant would be operational and
profitable in a timely manner
Mr. Kurre’s failure to comply was not excused;
(D) Mr. Kurre’s breach of the agreement that, if Mr. Gajarawala personally
guaranteed two loans from Allegiance Bank to Texas Concrete Enterprise, then Mr.
Kurre would work to ensure that the Kendleton Cement Plant would be operational and
profitable in a timely manner caused Mr. Gajarawala money damages totaling
(E) Mr. Kurre failed to comply with his fiduciary duty to Texas Concrete Enterprise;
(F) Mr. Kurre’s failure to comply with his fiduciary duty to Texas Concrete
Enterprise resulted in damages to the company totaling $0.00
(G) Mr. Kurre failed to comply with the Company Agreement of Texas Concrete
Enterprise dated October 14, 2014;
(H) Mr. Gajarawala failed to comply with the Company Agreement of Texas Concrete
Enterprise dated October 14, 2014;
Mr. Kurre failed to comply with the Company Agreement of Texas Concrete
Enterprise dated October 14, 2014 first;
(J) Mr. Kurre’s failure to comply with the Company Agreement of Texas Concrete
Enterprise dated October 14, 2014 was not excused;
(K) Mr. Kurre’s breach of the Company Agreement of Texas Concrete Enterprise
dated October 14, 2014caused Mr. Gajarawala damages totaling $300,000.00.
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(L) Mr. Gajarawala failed to comply with his fiduciary duty to Texas Concrete
Enterprise;
(M) Mr. Gajarawala’s failure to comply with his fiduciary duty to Texas Concrete
Enterprise resulted in damages to the company totaling $0.00. and
(N) Texas Concrete Enterprise and Mr. Gajarawala did not fail to comply with the
Memorandum of Understanding for the mixer trucks dated June 25, 2015.
II. Authority
Rule 301 of the Texas Rules of Civil Procedure permits a trialcourt to render a
judgment notwithstanding the verdict (“JNOV”) “if a directed verdict would have been proper.”
IV . 301. Rule 301 also permits a trial court to “disregard any jury’s finding on a
question that has no support in the evidence.” Id. Courts have held that a JNOV is proper when
(1) there is no evidence to support one or more of the jury findings on issues necessary to
liability, or (2) a legal principle precludes recovery Tiller v. McLure, 121 S.W.3d 709, 713
(Tex.2003); John Masek Corp. v. Davis, 848 S.W.2d 170, 173 (Tex.App. Houston [1st Dist.]
1992, writ denied).
Challenges to a trial court's ruling on a motion for JNOV are reviewed under the
same legal sufficiency test applied to appellate no evidence challenges. City of Keller v. Wilson
168 S.W.3d 802, 82223, 827 (Tex.2005).
Under that standard, the court considers the evidence in the light most favorable
to the verdict and indulge every reasonable inference that would support it. . at 822. The court
credits favorable evidence if reasonable jurors could, and disregards contrary evidence unless
reasonable jurors could not. . at 827. If more than a scintilla of probative evidence supports the
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finding, the legal sufficiency challenge fails. Coastal Transp. Co. v. Crown Cent. Petroleum
Corp., 136 S.W.3d 227, 233 (Tex.2004).
re than a scintilla of evidence exists when the evidence “rises to a level that
would enable reasonable and fair minded people to differ in their conclusions.” Transp. Ins. Co.
v. Moriel, 879 S.W.2d 10, 25 (Tex.1994). In contrast, evidence that creates no more than “a mere
surmise or suspicion of its existence” is only a scintilla and, thus, no evidence. Ford Motor Co. v.
Ridgway, 135 S.W.3d 598, 601 (Tex.2004) (quoting Kindred v. Con/Chem, Inc., 650 S.W.2d 61,
63 (Tex.1983)); see also Lozano v. LozanoS.W.3d 141, 148 (Tex.2001).
A jury's verdict or finding may be based on inferences that are fairly drawn from
the facts in evidence. Briones v. Levine's Dep't Store, Inc., 446 S.W.2d 7, 10 (Tex.1969); see also
Lozano, 52 S.W.3d at 149 (circumstantial evidence may be used to establish any material fact).
A vital fact, however, may not be established by piling inference upon inference. Schlumberger
Well Surveying Corp. v. Nortex Oil & Gas Corp., 435 S.W.2d 854, 858 (Tex.1969). Thus, “facts
from which an inference may properly be drawn must be established by direct evidence, not by
other inferences.” Entex, A Div. of Noram Energy Corp. v. Gonzalez, 94 S.W.3d 1, 8 (Tex.App.
Houston [14th Dist.] 2002, pet. denied).
III. Defendant’s Motion Fails
Breach of Agreement as to Personal Guarantee (Questions No. 1 andNo.4)
Defendant seeks judgment notwithstanding the verdict on the jury’s unanimous
finding to Question No. 1 and Question
enerally these two jury questions ask the jury to determine (1) whether Mr.
Gajarawala and Mr. Kurre agreed that, if Mr. Gajarawala personally guaranteed two loans from
Allegiance Bank to Texas Concrete Enterprise, then Mr. Kurre would work to ensure that the
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Kendleton Cement Plant would be operational and profitable in a timely manner and (2) what
damages should Kurre pay to Mr. Gajarawala as compensation for his breach of the agreement.
Defendant baldly states that “there was no contract”.
Significant evidence and testimony exists to establish that the parties in fact
agreed that, if Mr. Gajarawala personally guaranteed two loans from Allegiance Bank to Texas
Concrete Enterprise, then Mr. Kurre would work to ensure that the Kendleton Cement Plant
would be operational and profitable in a timely manner
In fact, the Court need not any further than Defendant’s own testimony. Mr.
Kurre testified that he agreed that it was not just his duty, but his fiduciary duty, to get the plant
up and running and profitable in a timely manner and that he entered into that agreement with
Mr. Gajarawala.
In that light Mr. Gajarawala testified that he would not have agreed to have the
company borrow money from Allegiance Bank and then have him personally guarantee the loans
if Defendant had not promised to get the plant up and running and profitable in a timely manner
and that such agreement was in fact discussed and entered into prior to the closing of the loans
with Allegiance Bank
The record is replete with evidence of an agreement and the jury agreed
unanimously with Mr. Gajarawala for Question
While Defendant solicited testimony that a personal guarantee is a general
requirement for a commercial loan transaction, he ignores the rest of the evidence that
establishes that Mr. Gajarawala would never have agreed to borrow money at all but for Mr.
Kurre’s promise.
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The jury weigh the evidence and unanimously found that such agreement in
fact existed.
With respect to Defendant’s bald claim that there is no evidence of damages
resulting from Defendant’s breach of the oral agreement, Defendant ignores the evidence and
testimony. More specifically Defendant ignores numerous exhibits that were pre admitted by his
agreement in this case.
There were various records pre admitted by Defendant that identify the moneys
spent by Mr. Gajarawala as a direct result of Mr. Kurre’s breach of the agreement and such
exhibits constitute much more than a scintilla of evidence.
The jury had ample opportunity to review those pre admitted exhibits and to
surmise that those financial documents, credit card statements, bank account records, copies of
checks, summary sheets, testimony, and the like established a damage amount the directly related
to Mr. Kurre’s breach of the agreement.
Finally, there is significant evidence for the jury to determine that the only reason
that the Allegiance loans were not called was because Mr. Gajarawala loaned the company in
excess of $1.7 million dollars and otherwise spent a lot of money to try to mitigate the losses
caused by Defendant’s breach of the agreement. This is both an injury and proof of monetary
damages that was not in any way excessive.
Defendant’s motion for judgment notwithstanding the verdict on these issues
should be denied.
Breach of Company Agreement
Defendant seeks judgment notwithstanding the verdict on the jury’s unanimous
finding to Question No 11 through 16
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enerally these jury questions ask the jury to determine whether Kurre or Mr.
Gajarawala breached the Company Agreement and, if they both did, who breached first hen
these questions seek a finding as to what damages Kurre should pay to Mr. Gajarawala as
compensation for r. Kurre’s breach of the Company Agreement.
gain the Court need not look any further than Defendant’s own testimony. Mr.
Kurre testified that he agreed that it was not just his duty, but his fiduciary duty, to, among other
things, get the plant up and running and profitable in a timely manner.
Defendant also admitted time and again that he willingly and intentionally quit
providing any capital or work for the company when this lawsuit was filed. Such act or inaction
is clearly a willful breach of the Company Agreement.
Moreover, the entirety of the Company Agreement was introduced into evidence
by Defendant and he jury reviewed said agreement after multiple jury questions to the Court
regarding its termsand similar matters
After such effort, the jury unanimously found that Mr. Kurre’s actions constituted
a breach of the Company Agreement.
Defendant’s assertion that “Conclusive Evidence establishes loans were invalid”
on page 3 of Defendant’s motion does not appear to make sense or to properly address any
particular jury question(s). Frankly Mr. Gajarawala does not know what this section means or
what it intends to address
With respect to Defendant’s bald claim that there is no evidence of damages
resulting from Defendant’s breach of the Company Agreement, Defendant ignores the evidence
and testimony.More specifically Defendant ignores numerous exhibits that were pre admitted in
this case.
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There were various records pre admitted agreement by Defendant that identify the
moneys spent by Mr. Gajarawala as a direct result of Mr. Kurre’s breach of the Company
Agreement. The jury had ample opportunity to review those records and to surmise that those
financial documents, credit card statements, bank account records, copies of checks summary
sheets, and testimony established a damage amount the directly related to Mr. Kurre’s breach of
the Company Agreement.
Defendant’s motion for judgment notwithstanding the verdict on these issues
should be denied.
WHEREFORE, Plaintiff Hemant Gajarawala (“Mr. Gajarawala”), and Plaintiff
Intervenor DEVSJ Concrete, LLC (“DEVSJ”) respectfully request that the Court deny
Defendant’s Motion for judgment notwithstanding the Verdict and enter the final judgment fi
by Plaintiff and Intervenor Plaintiff consistent with the jury’s verdict and that they each have
such other and further relief to which they may be justly entitled.
espectfully Submitted,
ATHERN
By:/s/ Isaac Villarreal
Isaac Villarreal
Texas Bar No.
ivillarreal@mccathernlaw.com
Eric M. Utermohlen
Texas Bar No. 24103974
ermohlen@mccathernlaw.com
2000 West Loop South, Suite 185
Houston, Texas 77027
Tel. (832) 533
Fax (832) 213
ATTORNEYS FOR PLAINTIFFAND
PLAINTIFF INTERVENOR
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CERTIFICATE OF SERVICE
I hereby certify that on this day of March, 2018, a true and correct copy of the
foregoing and/or attached was served on each attorney of record or party in accordance with the
Texas Rules of Civil Procedure as follows:
John D. Charbonnet, Jr. Via E file
OCHMAN HARBONNET
12012 Wickchester, Suite 150
Houston, Texas 77079
jdcharbonnet@kdclaw.com
Attorney for Defendant
/s/ Isaac Villarreal
Isaac Villarreal
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Preview
Cause No.2016-49450 HEMANT GAJARAWALA, Individually § IN THE DISTRICT COURT OF § Plaintiff, § § DEVSJ CONCRETE, LLC, derivatively on behalf § Of Texas Concrete Enterprise IV, LLC § HARRIS COUNTY, TEXAS Intervenor Plaintiff § § vs. § § SOMAIAH KURRE § § Defendant § 80 JUDICIAL DISTRICT PLAINTIFFAND INTERVENOR PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT SOMAIAH KURRE’S MOTION FOR JUDGMENT NOTWITHSTANDING THE VERDICT Plaintiff Hemant Gajarawala (“Mr. Gajarawala”), and Plaintiff Intervenor DEVSJ Concrete, LLC (“DEVSJ”) submit this Response to Def ndant Somaiah Kurre’s Motion for Judgment Notwithstanding the Verdict and states as follows: Background jury verdict in this case was rendered n favor of Pla tiff and DEVSJ and against Defendant Somaiah Kurre (“Defendant”) February 23 after 4 days of evidence was presented via various witnesses and trial exhibits tendered by the parties The unanimous verdict was adopted by the Court. By their verdict, the jury found that: (A) Mr. Gajarawala and Kurre agreed that, if Mr. Gajarawala personally guaranteed two loans from Allegiance Bank to Texas Concrete Enterprise, then Mr. Kurre would work to ensure that the Kendleton Cement Plant would be operational and profitable in a timely manner; Page of Mr. Kurre failed to comply with the agreement that, if Mr. Gajarawala personally guaranteed two loans from Allegiance Bank to Texas Concrete Enterprise, then Mr. Kurre would work to ensure that the Kendleton Cement Plant would be operational and profitable in a timely manner Mr. Kurre’s failure to comply was not excused; (D) Mr. Kurre’s breach of the agreement that, if Mr. Gajarawala personally guaranteed two loans from Allegiance Bank to Texas Concrete Enterprise, then Mr. Kurre would work to ensure that the Kendleton Cement Plant would be operational and profitable in a timely manner caused Mr. Gajarawala money damages totaling (E) Mr. Kurre failed to comply with his fiduciary duty to Texas Concrete Enterprise; (F) Mr. Kurre’s failure to comply with his fiduciary duty to Texas Concrete Enterprise resulted in damages to the company totaling $0.00 (G) Mr. Kurre failed to comply with the Company Agreement of Texas Concrete Enterprise dated October 14, 2014; (H) Mr. Gajarawala failed to comply with the Company Agreement of Texas Concrete Enterprise dated October 14, 2014; Mr. Kurre failed to comply with the Company Agreement of Texas Concrete Enterprise dated October 14, 2014 first; (J) Mr. Kurre’s failure to comply with the Company Agreement of Texas Concrete Enterprise dated October 14, 2014 was not excused; (K) Mr. Kurre’s breach of the Company Agreement of Texas Concrete Enterprise dated October 14, 2014caused Mr. Gajarawala damages totaling $300,000.00. Page of (L) Mr. Gajarawala failed to comply with his fiduciary duty to Texas Concrete Enterprise; (M) Mr. Gajarawala’s failure to comply with his fiduciary duty to Texas Concrete Enterprise resulted in damages to the company totaling $0.00. and (N) Texas Concrete Enterprise and Mr. Gajarawala did not fail to comply with the Memorandum of Understanding for the mixer trucks dated June 25, 2015. II. Authority Rule 301 of the Texas Rules of Civil Procedure permits a trialcourt to render a judgment notwithstanding the verdict (“JNOV”) “if a directed verdict would have been proper.” IV . 301. Rule 301 also permits a trial court to “disregard any jury’s finding on a question that has no support in the evidence.” Id. Courts have held that a JNOV is proper when (1) there is no evidence to support one or more of the jury findings on issues necessary to liability, or (2) a legal principle precludes recovery Tiller v. McLure, 121 S.W.3d 709, 713 (Tex.2003); John Masek Corp. v. Davis, 848 S.W.2d 170, 173 (Tex.App. Houston [1st Dist.] 1992, writ denied). Challenges to a trial court's ruling on a motion for JNOV are reviewed under the same legal sufficiency test applied to appellate no evidence challenges. City of Keller v. Wilson 168 S.W.3d 802, 82223, 827 (Tex.2005). Under that standard, the court considers the evidence in the light most favorable to the verdict and indulge every reasonable inference that would support it. . at 822. The court credits favorable evidence if reasonable jurors could, and disregards contrary evidence unless reasonable jurors could not. . at 827. If more than a scintilla of probative evidence supports the Page of finding, the legal sufficiency challenge fails. Coastal Transp. Co. v. Crown Cent. Petroleum Corp., 136 S.W.3d 227, 233 (Tex.2004). re than a scintilla of evidence exists when the evidence “rises to a level that would enable reasonable and fair minded people to differ in their conclusions.” Transp. Ins. Co. v. Moriel, 879 S.W.2d 10, 25 (Tex.1994). In contrast, evidence that creates no more than “a mere surmise or suspicion of its existence” is only a scintilla and, thus, no evidence. Ford Motor Co. v. Ridgway, 135 S.W.3d 598, 601 (Tex.2004) (quoting Kindred v. Con/Chem, Inc., 650 S.W.2d 61, 63 (Tex.1983)); see also Lozano v. LozanoS.W.3d 141, 148 (Tex.2001). A jury's verdict or finding may be based on inferences that are fairly drawn from the facts in evidence. Briones v. Levine's Dep't Store, Inc., 446 S.W.2d 7, 10 (Tex.1969); see also Lozano, 52 S.W.3d at 149 (circumstantial evidence may be used to establish any material fact). A vital fact, however, may not be established by piling inference upon inference. Schlumberger Well Surveying Corp. v. Nortex Oil & Gas Corp., 435 S.W.2d 854, 858 (Tex.1969). Thus, “facts from which an inference may properly be drawn must be established by direct evidence, not by other inferences.” Entex, A Div. of Noram Energy Corp. v. Gonzalez, 94 S.W.3d 1, 8 (Tex.App. Houston [14th Dist.] 2002, pet. denied). III. Defendant’s Motion Fails Breach of Agreement as to Personal Guarantee (Questions No. 1 andNo.4) Defendant seeks judgment notwithstanding the verdict on the jury’s unanimous finding to Question No. 1 and Question enerally these two jury questions ask the jury to determine (1) whether Mr. Gajarawala and Mr. Kurre agreed that, if Mr. Gajarawala personally guaranteed two loans from Allegiance Bank to Texas Concrete Enterprise, then Mr. Kurre would work to ensure that the Page of Kendleton Cement Plant would be operational and profitable in a timely manner and (2) what damages should Kurre pay to Mr. Gajarawala as compensation for his breach of the agreement. Defendant baldly states that “there was no contract”. Significant evidence and testimony exists to establish that the parties in fact agreed that, if Mr. Gajarawala personally guaranteed two loans from Allegiance Bank to Texas Concrete Enterprise, then Mr. Kurre would work to ensure that the Kendleton Cement Plant would be operational and profitable in a timely manner In fact, the Court need not any further than Defendant’s own testimony. Mr. Kurre testified that he agreed that it was not just his duty, but his fiduciary duty, to get the plant up and running and profitable in a timely manner and that he entered into that agreement with Mr. Gajarawala. In that light Mr. Gajarawala testified that he would not have agreed to have the company borrow money from Allegiance Bank and then have him personally guarantee the loans if Defendant had not promised to get the plant up and running and profitable in a timely manner and that such agreement was in fact discussed and entered into prior to the closing of the loans with Allegiance Bank The record is replete with evidence of an agreement and the jury agreed unanimously with Mr. Gajarawala for Question While Defendant solicited testimony that a personal guarantee is a general requirement for a commercial loan transaction, he ignores the rest of the evidence that establishes that Mr. Gajarawala would never have agreed to borrow money at all but for Mr. Kurre’s promise. Page of The jury weigh the evidence and unanimously found that such agreement in fact existed. With respect to Defendant’s bald claim that there is no evidence of damages resulting from Defendant’s breach of the oral agreement, Defendant ignores the evidence and testimony. More specifically Defendant ignores numerous exhibits that were pre admitted by his agreement in this case. There were various records pre admitted by Defendant that identify the moneys spent by Mr. Gajarawala as a direct result of Mr. Kurre’s breach of the agreement and such exhibits constitute much more than a scintilla of evidence. The jury had ample opportunity to review those pre admitted exhibits and to surmise that those financial documents, credit card statements, bank account records, copies of checks, summary sheets, testimony, and the like established a damage amount the directly related to Mr. Kurre’s breach of the agreement. Finally, there is significant evidence for the jury to determine that the only reason that the Allegiance loans were not called was because Mr. Gajarawala loaned the company in excess of $1.7 million dollars and otherwise spent a lot of money to try to mitigate the losses caused by Defendant’s breach of the agreement. This is both an injury and proof of monetary damages that was not in any way excessive. Defendant’s motion for judgment notwithstanding the verdict on these issues should be denied. Breach of Company Agreement Defendant seeks judgment notwithstanding the verdict on the jury’s unanimous finding to Question No 11 through 16 Page of enerally these jury questions ask the jury to determine whether Kurre or Mr. Gajarawala breached the Company Agreement and, if they both did, who breached first hen these questions seek a finding as to what damages Kurre should pay to Mr. Gajarawala as compensation for r. Kurre’s breach of the Company Agreement. gain the Court need not look any further than Defendant’s own testimony. Mr. Kurre testified that he agreed that it was not just his duty, but his fiduciary duty, to, among other things, get the plant up and running and profitable in a timely manner. Defendant also admitted time and again that he willingly and intentionally quit providing any capital or work for the company when this lawsuit was filed. Such act or inaction is clearly a willful breach of the Company Agreement. Moreover, the entirety of the Company Agreement was introduced into evidence by Defendant and he jury reviewed said agreement after multiple jury questions to the Court regarding its termsand similar matters After such effort, the jury unanimously found that Mr. Kurre’s actions constituted a breach of the Company Agreement. Defendant’s assertion that “Conclusive Evidence establishes loans were invalid” on page 3 of Defendant’s motion does not appear to make sense or to properly address any particular jury question(s). Frankly Mr. Gajarawala does not know what this section means or what it intends to address With respect to Defendant’s bald claim that there is no evidence of damages resulting from Defendant’s breach of the Company Agreement, Defendant ignores the evidence and testimony.More specifically Defendant ignores numerous exhibits that were pre admitted in this case. Page of There were various records pre admitted agreement by Defendant that identify the moneys spent by Mr. Gajarawala as a direct result of Mr. Kurre’s breach of the Company Agreement. The jury had ample opportunity to review those records and to surmise that those financial documents, credit card statements, bank account records, copies of checks summary sheets, and testimony established a damage amount the directly related to Mr. Kurre’s breach of the Company Agreement. Defendant’s motion for judgment notwithstanding the verdict on these issues should be denied. WHEREFORE, Plaintiff Hemant Gajarawala (“Mr. Gajarawala”), and Plaintiff Intervenor DEVSJ Concrete, LLC (“DEVSJ”) respectfully request that the Court deny Defendant’s Motion for judgment notwithstanding the Verdict and enter the final judgment fi by Plaintiff and Intervenor Plaintiff consistent with the jury’s verdict and that they each have such other and further relief to which they may be justly entitled. espectfully Submitted, ATHERN By:/s/ Isaac Villarreal Isaac Villarreal Texas Bar No. ivillarreal@mccathernlaw.com Eric M. Utermohlen Texas Bar No. 24103974 ermohlen@mccathernlaw.com 2000 West Loop South, Suite 185 Houston, Texas 77027 Tel. (832) 533 Fax (832) 213 ATTORNEYS FOR PLAINTIFFAND PLAINTIFF INTERVENOR Page of CERTIFICATE OF SERVICE I hereby certify that on this day of March, 2018, a true and correct copy of the foregoing and/or attached was served on each attorney of record or party in accordance with the Texas Rules of Civil Procedure as follows: John D. Charbonnet, Jr. Via E file OCHMAN HARBONNET 12012 Wickchester, Suite 150 Houston, Texas 77079 jdcharbonnet@kdclaw.com Attorney for Defendant /s/ Isaac Villarreal Isaac Villarreal Page of