Preview
........__________
06/19/2006 16:45 8174241665 GREGORY G JONES PAGE 03/09
CAUSE NO. 348-211577-05
CORRAL GROUP, LP § IN THE DISTRICT COURT
Plaintiff, §
§
v. § 348tb JUDICIAL DISTRICT
§
SMIC, LTD., WINTERSTONE §
MANAGEMENT, INC., JH & BC §
CORP., 13:30 CORP., POWER §
DEVELOPMENT, INC., D. RONALD §
ALLEN, AND ARNOLD V. PENT, et. §
al. §
Defendant. § TARRANT COUNTY, "'
TExA~, '}
PLAINTIFF'S RESPONSE TO MOTION TO CANCEL LIS PENDENS:·
,.·.,.·
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW Corral Group, LP. Plaintiff, and files Response to Motion to Cancel Lis
Pendens, and would respectfully show the Court as follows:
I. BACKGROUND
This dispute in this case involves the sale of a property in Tarrant County. Plaintiff bad ·
in place a contract to purchase the property, and was ready and able to buy. Before Plaintiffs
contract was completed, in:validated, or cancelled by the sellers, the sellm entered into another
contract to sell the property to defendant Highway 199 & Charbonneau Partners (Charbonneau)
through negotiations with its parent N3 Capital LLC (N3). 1 Charbonneau and N3 were aware of
the pre-existing contract with Plaintiff, yet went forward with the purchase of the property
anyway, and tortiously interfered with the :Plaintiff's contract.
Deposition Exhibit 36 and 37 are and example of the evidence in this case which shows
that N3 and Charbonneau knew that the plaintiff was being misled about the purchase of the
property, and participated in the fraud that was being conducted. Exhibit 36 is a series of e-ma:ils
1
Defendant Highway 199 & Charbonneau Partners was created by N3 Capital LLC to purchase and OVI'll the
propeJ.ty in question on or about February 1, 2005.
The property in question is located at the intersection of
Hi&hway 199 and Charbonneau Road in Tanant County, Texas.
06/19/2006 16:45 8174241665 GREGORY G JONES PAGE 04/09
between the sellers and N3 discussing the agre~ment not to infonn the plaintiff that the property
in question was wtder a second contract. Furthermore they are discussing sru1ding a letter to the
Plaintiff which suggests that the Plaintiff's contract is still valid. N3 asks that they go forward
and send the letter misrepresenting the status of the transaction. Exhibit 37 is a copy of the letter
that was being discussed by N3 and the sellers, and it is clear that it is written as if the contract
between Corral and the sellers is still valid and enforceable.
When plaintiff initially filed this lawsuit, it was unaware that Charbonneau and N3 were
complicit in the fraud and misr~resentations made to th~ Plaintiff and tlle breach of the
plaintiff's contract. Representations were made that Charbonneau was an innocent purchaser of
the property. unaware of the seller's fraudulent conduct. which prompted plaintiff to cancel the
original lis pendens. During the course of this lawsuit plaintiff became aware that Charbonneau
was not an innocent purchaser, the lis pendens was reinstituted.
II. ARGUMENT AND AUTHORITIES
The Plaintiff cannot be adequately protected by the deposit of money as contemplated by
Tex. Prop. Code § 12.008. One of the remedies requested by the plaintiffs is specific
performance under their contract; the deposit of money alone will not adequately protect the
Plaintiffs ri~ts in this case.
Furthennore, Tex. Prop. Code§ 12.008 requires the movant to provide evidence that the
Plaintiff is adequately protected by the deposit of money, and the :movant has not met this
burden.
Defendant Charbonneau requests the court to lift the lis pendens so that it may continue
to develop and sell the property in question. The court should not pennit this defendant to
continue to profit from its wrongful actions. Furthermore, keeping the lis pendens in place does
not prohibit movant from development and/or sale of the property in question. Group
PLAINTIFF'S R:ESPONSE TO MOTION TO CANCEL US PENDENS Page 2
........___________
06/19/2006 16:45 8174241665 GREGORY G JONES PAGE 05/09
Purchases, Inc. v. Lance Investments, Inc., 685 S.W.2d 729, 731-2 (Tex. App.-Dallas 1985,
writ ref. n.r.e.). It does serve to wam future purchasers of the property of the dispute however,
and for that reason should be kept in place. If the court permits the dissolution of the lis
pendens, then Charbonneau could effectively render moot any decision regarding the ownership
of the property by selling it to a third party who did not have notice of the ownership dispute. Jd.
This in turn, would likely lead to additional litigation.
WHEREFORE PREMSffiS CONSIDERED, Plaintiff respectfully requests that
Defendants motion. be denied, that the lis pettdens stay in place on the property in. question and
for such other reliefto which it may be justly entitled.
-go yG. Jo es
Texas ar • 10889370
603 So tl ain St, Ste. 200
Grapevine; Texas 76051
Telephone: (817) 424-9001
Facsimile: (817) 424-1665
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing instrument has been served
upon the Attorney of Record of all parties to the above entitled and num ed cause ill
accordance with the RULES OF CIVJ.l. PROCEDURE on this day of 1 e 2006, by the
following:
personal delivery
--K' telecopies (facsimile) tr:an.s;rp~
certified mail
regular mail
Pl.AlNTIFF'S RESPONSE TO MOTION TO CANCEL LIS PENDENS Page3
......____________
06/19/2006 16:45 8174241665 GREGORy G JONES PAGE 06/09
....
\
Page I of2
Arnold Pent
From: "Arnold Penf'
To: "Ron Allen"
Cc::: "Jason Keeny
Sent: Friday, March 11, 2005 9:50AM '
t
Attach: SMIC-GoldenCori:aiSiteProblems.doe
Subject: Fw: Golden Corral ·
Ron .A.llen
Jason I
To:~>;
Cc:
Sent: Th.m-sday, March 10,2005 :5:17PM
Subject: Re: Golden Co:tal . I
> Arnold. I am out today. I will not contact the GC person. I rev~ewed
your letter and is fine with me. Please send it to him and let me khow wha:t
he says. Time is of the essence. !
>
> Thanks for your help.
>
>JK.
>
> ----~Original Message-----
> From; Arnold Pent ·
> To: Je.son Keen
> Ce: Ron Allen
>Sent: Mar JO, zoos 3;03p ·
I·
> Subject: :R.e: Oolden Corral ' I
; Jason, looking forward to your caU today on the GC proposed l~~. L~ft
a message on your cell. . · ·
>
>We would prefer that GC not be contaCted at this point except tfuough this
letter and Ron and I have agreed at this juncture that we will tenni!nate
4/5/2006
.......----------- GREGORY G JONES
PAGE 07/09
8174241665 Page2of2
06/19/2006 16:45
I,
this conttact on your date of closing April1 st. With the informa:~ton
gathered, it is clear to us tbitt they dropped the ball on the survey ssue,
the contract is expired. However, we're not prepared to upset the apple
cart until yolll' day of closing. 1 trUSt that is acceptable to you.
·
=-~-
>
>
>
-~-- Original Message ----
From: JasOn J.(een
io: Arnold Pent
. \i
·I
\
> Sent: Wednesday, March 09,2005 6:09PM
> Subject: Golden Corral
> i
> Hi Arnold, when you get a chance, will you send me the purcliase:rs
contact infonnation? 1 need to make contact with him. l
> \
> \'
> \'
> ThaDlcs.
>
>
>
> ------·----------~-----------------~-----------------~-----~~---~-----
>
>
> JasonK.een
( >
> N3 CAPITAL LLC
> 301 Coxnmerce St. Suite 3131
>
>
> Fort Worth, TX 76102
>
> 0: 817.348.8748.
>
> F: 8 1'7.348.8468
>
> c~ 214.:517.9700
>
JI
>
ww:J!..t:i3C:apital.cQm
>
>
>
>
'>
( 4/5/Z006
PAGE 08/09
GREGORY G JONES
06/19/2006 16:45 8174241665
' .
I
1
Memo
Date: Maxch 9. 2005
Via Fax 972 381 1211
To: Ron Allen Via Fax 817 348 8468
Jason Keen
Fro:rn: Arnold Pent
Subject:
Golden Corral Group LLC
\ .
Ple~ :review the PROPOSED letter to Golden Corral an4 comn'l.en.t back to me beforel
complete it and mail to Golden Corral via regular mall. JTon, please calculate the
distance called for in the letter and advise. · ·
Note the additional information from the Dunaway prop*o letter to Golden Corral dated
October 6, :Z004. This p:roposal was not entered into by
calls for tbe Pux'chaser to ordq a survey. It appears from.
fo,....ro witb. it. hence the delayod action in obtainWg • til lden Corral. The ¢9ntract
·s evidence they failed to go
policy .,til JanU"'l' 2005.
.
(
______________________....
06/19/2006 16:45 8174241665 GREGORY G JONES PAGE 09/09
i
SMIC,Ltd.. l
17300 N. Dallas Plcwy, Suit, 2040
'·.
Dallas, TX 7S248 !
1
I DEPOSITION
March 11. 2005 $ EXHIBIT
!!l 30
I Atle.'V\_
Mr. Guillermo Parales
Cori'al Group, LLC
7750 N. MacArthur Blvd., #120-221
Irving, Texas 75063 ,
Re: .Golden Corral Group, LLC/SMIC, Ltd. Cont
Lake Worth, Fort Worth, Texas 1I
I
ct Dated July 28, 2004
Dear Mr. Perales: I
. I
Enclosed is a letter received from our engineer after mee!fgs with the cities of Lake
Worth anq Fort Worth. As you will see, Lake Wonh is il:pposing an on-site detention
facility which will ir.npact the efficient use of the site. j ·
. i
Additionally, the Texas Department ofTransportation·wilil. only grant a. curb cut permit at
the point where the Mancbu Wok store would be. This e~ent places its viability on the
..
~-·
l site in jeopardy. !
\ ... I
Another difficulty which stllfaced during the preliminacy ~lat discussions was the
requirement of the city of Lake Worth to dedicate an add.i~ional 8' of right of way for the
improveme~t of Clw:'bonn.eau. I ·
Please advise concerning your assessment of these events~ it relates to your former
plans. j .
Sincerely~ i
Arnold Pent
Enclosure
Cc; Ron Allen
Torn Paredes
File: SMIC~~GoldenCort'alSiteProblems
/
..
...
06/19/2006 16:45 8174241665 GREGORY G JONES PAGE 02/09
LAW FIRM OF GREGORY G. JONES. P.C.
603 S. MAIN ST. SUITE 200
GRAPE~ TEXAS 76051
GregQry G. Jones
Board Cm'tifled: PERSONAL INJU.R.Y nuAL Metro Telephone Number: 817-424·9001
LAW ana CIVIL T.RJAJ... I.AW by tbe TEXAS Metro FIIX Number: 817-42.4·1665
BOARD OF LEGAL SPECIALIZATION E-mail Address:greg@gioncsls.w,com
Pandcpl: Rebccca@ajoneslaw.com
CML TR:IAl. SP£ClA.Ll:ST
NAtiONAL BOARD OF TRIAL NJVOCACY
June 19, 2006
VIA FAX FILING
Clerk
348111 Judicial District Cort
401 West Belknap
Fort Wortb, TX 76196
Re: Corral Group, L.L.C. v. SMJC, Ltd
Cause No. 348-211S77-05; In the 348th Judicial District Court, Tarrant County
Dear Clerk:
Enclosed are the following documents to be filed in the above-referenced case:
1. Plaintiff's Resposne to Motion to Cancel Lis Pendens
By copy of this letter, J. am forwarding via facsimile, a true and correct copy of the enclosed
document to opposing counsel.
Please do not hesitate to contact me should you have any questions concerning this ma\ter•
,-·.·,,
,,
.,1
R.J
B .um CERTIFIED LEGAL ASST- PERSONAL INJURY TRIAL LAW
XAS BOARD OF LEGAL SPECIALIZATION
Enclosure
cc: Mr. J. Cort DeHart VlA FAX (817) 810-0499
3340 Camp Bowie Boulevard, Suite 100
Fort Worth, Texas 76107
Mark D. Winnubst VIA FAX (972) 644-8180
Sheils Winnubst Sanford & Bethune
1100 Atrium II
1701 N. Collins Blvd
Richardson, TX 75080
Mr. William Jenkins. VIA FA)( (817} 334-7290
Jackson Walker
301 Commerce Street, Suite 2400
Fort Worth, TX 76102-4140
06/19/2006 16:45 8174241665 GREGORY G JONES PAGE 01/09
. -il·- •. -
09/21/00 TBtt 14:00 FA! 817 212 7010 TARRANT COUNTY ~002
Thomas A. Wilder * Tarrant Cotmty District Clerk
Fax Filing Transmittal Form· ~
Sent By
Attc:Jmey Name: C!:>~oo/ {6, J..oNE5 IQ O<>WIIlent
l'l:lmfloiP~C~\vbu~ Aadrasa T)'llSdSIIN'~
Con,;lable. Sl>t:riff Of' othl!l'
1.
2.
3.
4.
5.
D Petition previou~ 'iilec!: .seMce ~:~;>pie~ r.eing falced
0 See the followirtg for addlllonz,lii'I~Lidions
Preview
........__________ 06/19/2006 16:45 8174241665 GREGORY G JONES PAGE 03/09 CAUSE NO. 348-211577-05 CORRAL GROUP, LP § IN THE DISTRICT COURT Plaintiff, § § v. § 348tb JUDICIAL DISTRICT § SMIC, LTD., WINTERSTONE § MANAGEMENT, INC., JH & BC § CORP., 13:30 CORP., POWER § DEVELOPMENT, INC., D. RONALD § ALLEN, AND ARNOLD V. PENT, et. § al. § Defendant. § TARRANT COUNTY, "' TExA~, '} PLAINTIFF'S RESPONSE TO MOTION TO CANCEL LIS PENDENS:· ,.·.,.· TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW Corral Group, LP. Plaintiff, and files Response to Motion to Cancel Lis Pendens, and would respectfully show the Court as follows: I. BACKGROUND This dispute in this case involves the sale of a property in Tarrant County. Plaintiff bad · in place a contract to purchase the property, and was ready and able to buy. Before Plaintiffs contract was completed, in:validated, or cancelled by the sellers, the sellm entered into another contract to sell the property to defendant Highway 199 & Charbonneau Partners (Charbonneau) through negotiations with its parent N3 Capital LLC (N3). 1 Charbonneau and N3 were aware of the pre-existing contract with Plaintiff, yet went forward with the purchase of the property anyway, and tortiously interfered with the :Plaintiff's contract. Deposition Exhibit 36 and 37 are and example of the evidence in this case which shows that N3 and Charbonneau knew that the plaintiff was being misled about the purchase of the property, and participated in the fraud that was being conducted. Exhibit 36 is a series of e-ma:ils 1 Defendant Highway 199 & Charbonneau Partners was created by N3 Capital LLC to purchase and OVI'll the propeJ.ty in question on or about February 1, 2005. The property in question is located at the intersection of Hi&hway 199 and Charbonneau Road in Tanant County, Texas. 06/19/2006 16:45 8174241665 GREGORY G JONES PAGE 04/09 between the sellers and N3 discussing the agre~ment not to infonn the plaintiff that the property in question was wtder a second contract. Furthermore they are discussing sru1ding a letter to the Plaintiff which suggests that the Plaintiff's contract is still valid. N3 asks that they go forward and send the letter misrepresenting the status of the transaction. Exhibit 37 is a copy of the letter that was being discussed by N3 and the sellers, and it is clear that it is written as if the contract between Corral and the sellers is still valid and enforceable. When plaintiff initially filed this lawsuit, it was unaware that Charbonneau and N3 were complicit in the fraud and misr~resentations made to th~ Plaintiff and tlle breach of the plaintiff's contract. Representations were made that Charbonneau was an innocent purchaser of the property. unaware of the seller's fraudulent conduct. which prompted plaintiff to cancel the original lis pendens. During the course of this lawsuit plaintiff became aware that Charbonneau was not an innocent purchaser, the lis pendens was reinstituted. II. ARGUMENT AND AUTHORITIES The Plaintiff cannot be adequately protected by the deposit of money as contemplated by Tex. Prop. Code § 12.008. One of the remedies requested by the plaintiffs is specific performance under their contract; the deposit of money alone will not adequately protect the Plaintiffs ri~ts in this case. Furthennore, Tex. Prop. Code§ 12.008 requires the movant to provide evidence that the Plaintiff is adequately protected by the deposit of money, and the :movant has not met this burden. Defendant Charbonneau requests the court to lift the lis pendens so that it may continue to develop and sell the property in question. The court should not pennit this defendant to continue to profit from its wrongful actions. Furthermore, keeping the lis pendens in place does not prohibit movant from development and/or sale of the property in question. Group PLAINTIFF'S R:ESPONSE TO MOTION TO CANCEL US PENDENS Page 2 ........___________ 06/19/2006 16:45 8174241665 GREGORY G JONES PAGE 05/09 Purchases, Inc. v. Lance Investments, Inc., 685 S.W.2d 729, 731-2 (Tex. App.-Dallas 1985, writ ref. n.r.e.). It does serve to wam future purchasers of the property of the dispute however, and for that reason should be kept in place. If the court permits the dissolution of the lis pendens, then Charbonneau could effectively render moot any decision regarding the ownership of the property by selling it to a third party who did not have notice of the ownership dispute. Jd. This in turn, would likely lead to additional litigation. WHEREFORE PREMSffiS CONSIDERED, Plaintiff respectfully requests that Defendants motion. be denied, that the lis pettdens stay in place on the property in. question and for such other reliefto which it may be justly entitled. -go yG. Jo es Texas ar • 10889370 603 So tl ain St, Ste. 200 Grapevine; Texas 76051 Telephone: (817) 424-9001 Facsimile: (817) 424-1665 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument has been served upon the Attorney of Record of all parties to the above entitled and num ed cause ill accordance with the RULES OF CIVJ.l. PROCEDURE on this day of 1 e 2006, by the following: personal delivery --K' telecopies (facsimile) tr:an.s;rp~ certified mail regular mail Pl.AlNTIFF'S RESPONSE TO MOTION TO CANCEL LIS PENDENS Page3 ......____________ 06/19/2006 16:45 8174241665 GREGORy G JONES PAGE 06/09 .... \ Page I of2 Arnold Pent From: "Arnold Penf' To: "Ron Allen" Cc::: "Jason Keeny Sent: Friday, March 11, 2005 9:50AM ' t Attach: SMIC-GoldenCori:aiSiteProblems.doe Subject: Fw: Golden Corral · Ron .A.llen Jason I To:~>; Cc: Sent: Th.m-sday, March 10,2005 :5:17PM Subject: Re: Golden Co:tal . I > Arnold. I am out today. I will not contact the GC person. I rev~ewed your letter and is fine with me. Please send it to him and let me khow wha:t he says. Time is of the essence. ! > > Thanks for your help. > >JK. > > ----~Original Message----- > From; Arnold Pent · > To: Je.son Keen > Ce: Ron Allen >Sent: Mar JO, zoos 3;03p · I· > Subject: :R.e: Oolden Corral ' I ; Jason, looking forward to your caU today on the GC proposed l~~. L~ft a message on your cell. . · · > >We would prefer that GC not be contaCted at this point except tfuough this letter and Ron and I have agreed at this juncture that we will tenni!nate 4/5/2006 .......----------- GREGORY G JONES PAGE 07/09 8174241665 Page2of2 06/19/2006 16:45 I, this conttact on your date of closing April1 st. With the informa:~ton gathered, it is clear to us tbitt they dropped the ball on the survey ssue, the contract is expired. However, we're not prepared to upset the apple cart until yolll' day of closing. 1 trUSt that is acceptable to you. · =-~- > > > -~-- Original Message ---- From: JasOn J.(een io: Arnold Pent . \i ·I \ > Sent: Wednesday, March 09,2005 6:09PM > Subject: Golden Corral > i > Hi Arnold, when you get a chance, will you send me the purcliase:rs contact infonnation? 1 need to make contact with him. l > \ > \' > \' > ThaDlcs. > > > > ------·----------~-----------------~-----------------~-----~~---~----- > > > JasonK.een ( > > N3 CAPITAL LLC > 301 Coxnmerce St. Suite 3131 > > > Fort Worth, TX 76102 > > 0: 817.348.8748. > > F: 8 1'7.348.8468 > > c~ 214.:517.9700 > JI > ww:J!..t:i3C:apital.cQm > > > > '> ( 4/5/Z006 PAGE 08/09 GREGORY G JONES 06/19/2006 16:45 8174241665 ' . I 1 Memo Date: Maxch 9. 2005 Via Fax 972 381 1211 To: Ron Allen Via Fax 817 348 8468 Jason Keen Fro:rn: Arnold Pent Subject: Golden Corral Group LLC \ . Ple~ :review the PROPOSED letter to Golden Corral an4 comn'l.en.t back to me beforel complete it and mail to Golden Corral via regular mall. JTon, please calculate the distance called for in the letter and advise. · · Note the additional information from the Dunaway prop*o letter to Golden Corral dated October 6, :Z004. This p:roposal was not entered into by calls for tbe Pux'chaser to ordq a survey. It appears from. fo,....ro witb. it. hence the delayod action in obtainWg • til lden Corral. The ¢9ntract ·s evidence they failed to go policy .,til JanU"'l' 2005. . ( ______________________.... 06/19/2006 16:45 8174241665 GREGORY G JONES PAGE 09/09 i SMIC,Ltd.. l 17300 N. Dallas Plcwy, Suit, 2040 '·. Dallas, TX 7S248 ! 1 I DEPOSITION March 11. 2005 $ EXHIBIT !!l 30 I Atle.'V\_ Mr. Guillermo Parales Cori'al Group, LLC 7750 N. MacArthur Blvd., #120-221 Irving, Texas 75063 , Re: .Golden Corral Group, LLC/SMIC, Ltd. Cont Lake Worth, Fort Worth, Texas 1I I ct Dated July 28, 2004 Dear Mr. Perales: I . I Enclosed is a letter received from our engineer after mee!fgs with the cities of Lake Worth anq Fort Worth. As you will see, Lake Wonh is il:pposing an on-site detention facility which will ir.npact the efficient use of the site. j · . i Additionally, the Texas Department ofTransportation·wilil. only grant a. curb cut permit at the point where the Mancbu Wok store would be. This e~ent places its viability on the .. ~-· l site in jeopardy. ! \ ... I Another difficulty which stllfaced during the preliminacy ~lat discussions was the requirement of the city of Lake Worth to dedicate an add.i~ional 8' of right of way for the improveme~t of Clw:'bonn.eau. I · Please advise concerning your assessment of these events~ it relates to your former plans. j . Sincerely~ i Arnold Pent Enclosure Cc; Ron Allen Torn Paredes File: SMIC~~GoldenCort'alSiteProblems / .. ... 06/19/2006 16:45 8174241665 GREGORY G JONES PAGE 02/09 LAW FIRM OF GREGORY G. JONES. P.C. 603 S. MAIN ST. SUITE 200 GRAPE~ TEXAS 76051 GregQry G. Jones Board Cm'tifled: PERSONAL INJU.R.Y nuAL Metro Telephone Number: 817-424·9001 LAW ana CIVIL T.RJAJ... I.AW by tbe TEXAS Metro FIIX Number: 817-42.4·1665 BOARD OF LEGAL SPECIALIZATION E-mail Address:greg@gioncsls.w,com Pandcpl: Rebccca@ajoneslaw.com CML TR:IAl. SP£ClA.Ll:ST NAtiONAL BOARD OF TRIAL NJVOCACY June 19, 2006 VIA FAX FILING Clerk 348111 Judicial District Cort 401 West Belknap Fort Wortb, TX 76196 Re: Corral Group, L.L.C. v. SMJC, Ltd Cause No. 348-211S77-05; In the 348th Judicial District Court, Tarrant County Dear Clerk: Enclosed are the following documents to be filed in the above-referenced case: 1. Plaintiff's Resposne to Motion to Cancel Lis Pendens By copy of this letter, J. am forwarding via facsimile, a true and correct copy of the enclosed document to opposing counsel. Please do not hesitate to contact me should you have any questions concerning this ma\ter• ,-·.·,, ,, .,1 R.J B .um CERTIFIED LEGAL ASST- PERSONAL INJURY TRIAL LAW XAS BOARD OF LEGAL SPECIALIZATION Enclosure cc: Mr. J. Cort DeHart VlA FAX (817) 810-0499 3340 Camp Bowie Boulevard, Suite 100 Fort Worth, Texas 76107 Mark D. Winnubst VIA FAX (972) 644-8180 Sheils Winnubst Sanford & Bethune 1100 Atrium II 1701 N. Collins Blvd Richardson, TX 75080 Mr. William Jenkins. VIA FA)( (817} 334-7290 Jackson Walker 301 Commerce Street, Suite 2400 Fort Worth, TX 76102-4140 06/19/2006 16:45 8174241665 GREGORY G JONES PAGE 01/09 . -il·- •. - 09/21/00 TBtt 14:00 FA! 817 212 7010 TARRANT COUNTY ~002 Thomas A. Wilder * Tarrant Cotmty District Clerk Fax Filing Transmittal Form· ~ Sent By Attc:Jmey Name: C!:>~oo/ {6, J..oNE5 IQ O<>WIIlent l'l:lmfloiP~C~\vbu~ Aadrasa T)'llSdSIIN'~ Con,;lable. Sl>t:riff Of' othl!l' 1. 2. 3. 4. 5. D Petition previou~ 'iilec!: .seMce ~:~;>pie~ r.eing falced 0 See the followirtg for addlllonz,lii'I~Lidions