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CAUSE NO. 202233408
AMANEH SANAA ISPAHANY, IN THE DISTRICT COURT OF
Individually, and as Next Friend of A.J.
(Minor)
Plaintiff,
HARRIS COUNTY, TEXAS
SUGAR LAND URBAN AIR, LLC,
PEARLAND URBAN AIR, LLC,
UATP MANAGEMENT, LLC
UATP HOLDINGS, LLC &
ROCKWOOD ALLIANCES, INC.
D/B/A ROCKWOOD BUILDERS
Defendants. TH JUDICIAL DISTRICT
DEFENDANTS SUGAR LAND URBAN AIR, LLC; PEARLAND URBAN AIR, LLC;
UATP MANAGEMENT, LLC; AND UATP HOLDINGS, LLC’S
MOTION TO TRANSFER VENUE
NOW COME Defendants Sugar Land Urban Air, LLC (“Sugar Land”), Pearland Urban
Air, LLC (“Pearland”), UATP Management, LLC (“UATP Management”), and UATP Holdings,
LLC’s (“UATP Holdings”), and file their Motion to Transfer Venue pursuant to Texas Rules of
Civil Procedure 86 and Texas Civil Practice and Remedies Code, § 15.002(b), asking this Court
to transfer venue of this cause from Harris County, Texas to Fort Bend County, Texas, since the
events giving rise to Plaintiffs’ Petition took place in Fort Bend County, Texas. In addition, a
contract governing waiver, release, and arbitration of the claims alleged by Plaintiffs mandates
venue is properly Fort Bend County, Texas. Plaintiffs improperly joined Pearland in this action
in an effort to proceed in an improper venue. In support thereof, Defendants respectfully state as
follows:
DEFENDANTS SUGAR LAND URBAN AIR, LLC; PEARLAND URBAN AIR, LLC; UATP
MANAGEMENT, LLC; UATP HOLDINGS, LLC’S MOTION TO TRANSFER VENUE AGE
I. FACTUAL BACKGROUND
Plaintiffs Amaneh Sanaa Ispahany and minor plaintiff A.J, (hereinafter “Minor
Plaintiff”), upon information and belief, are residents of Fort Bend County, Texas and brought this
lawsuit against Defendants as the result of a June 4, 2022 incident that allegedly occurred at the
Urban Air Trampoline Park located at 9848 US-90 ALT, Sugar Land, Texas 77487. See Plaintiffs’
Original Petition. This incident occurred in Fort Bend County, where Sugar Land operates and
has its principal place of business.
Plaintiffs allege negligence, premises liability, negligence per se, and negligent
misrepresentation causes of action against all Defendants.
Plaintiffs allege that venue in Harris County is proper, based on the assertion that
Defendants Pearland and Rockwood Alliances, Inc. have principal offices in Harris County. See
Plaintiffs’ Original Petition
Pearland is improperly named in this litigation. Therefore, venue cannot rely on
Pearland’s principal offices.
II. ARGUMENT AND AUTHORITY
5. In the interest of justice and for the convenience of the parties and witnesses, this
matter should be transferred to Fort Bend County, pursuant to Tex. Civ. Prac. & Rem. Code §
15.002(b). The accident at issue occurred in Fort Bend County and Sugar Land and its principal
member reside in Fort Bend County. In addition, most of the anticipated witnesses, including
Plaintiffs, live in Fort Bend County. Moreover, there is contractual agreement governing the
allegations here, which mandates this dispute should proceed in Fort Bend County.
A. ERMISSIVE ENUE RUMPS ENERAL ENUE ULES.
Tex. Civ. Prac. & Rem. Code § 15.035 provides that permissive venue exists if a
person has contracted in writing to perform an obligation in a particular county and expressly
DEFENDANTS SUGAR LAND URBAN AIR, LLC; PEARLAND URBAN AIR, LLC; UATP
MANAGEMENT, LLC; UATP HOLDINGS, LLC’S MOTION TO TRANSFER VENUE AGE
names the county or a definite place in that county. The reported legal guardian of Minor Plaintiff
executed a Release and Indemnification Agreement (“Agreement”) for Sugar Land which: (1)
contains an arbitration agreement (which Sugar Land does not waive) and (2) provides that
“[v]enue for any action brought hereunder or due to Participant’s use of the Premises or
participation in the Activities shall lie in the County in which the Premises is located.” See
Agreement, attached hereto as Exhibit “A.” Here, “the County in which the Premises is located”
is Fort Bend County.
Plaintiffs allege personal injuries at a trampoline park located at 9848 US-90 ALT,
Sugar Land, TX 77478. This is physically located in Fort Bend County, Texas. The Agreement
expressly states that the activities governed by the Agreement may occur in, about, or near 9848
Hwy 90A, Sugar Land, TX 77478. Exhibit A, ¶ 9. Therefore, Fort Bend County, Texas is the
proper venue. “If no mandatory provision applies, the permissive venue provision allows suits
involving specific types of claims to be brought in certain counties [citations omitted]. If no
mandatory or permissive venue provision governs the claim at issue, the general rules will apply.”
Scott Law Offices v. Quinney Holdings, LLC, No. 01-19-00739-CV, 2020 WL 4006438, at *3
(Tex. App.—Houston [1st Dist.] July 16, 2020, no pet.).
Because there is a permissive venue applicable to the claims at issue in this lawsuit,
as stated by the Agreement, the Court should transfer this lawsuit to Fort Bend County, Texas.
B. PECIFIC ENIAL OF ENUE UE TO RAUDULENT OINDER OF ARTY
9. In addition, Tex. Civ. Prac. & Rem. Code § 15.002(a)(1) states that a lawsuit shall
be brought in the county in which all or a substantial part of the events or omissions giving rise to
Sugarland will move to compel arbitration once the Court issues it’s ruling on the motion to
transfer venue.
DEFENDANTS SUGAR LAND URBAN AIR, LLC; PEARLAND URBAN AIR, LLC; UATP
MANAGEMENT, LLC; UATP HOLDINGS, LLC’S MOTION TO TRANSFER VENUE AGE
the claim occurred. Here, the events or omissions giving rise to this lawsuit occurred in Fort Bend
County Texas at the Sugar Land premises.
Moreover, § 15.002(a)(3) provides that venue is proper in the county of the
defendant’s principal office in Texas. Sugar Land maintains its principal office in Fort Bend
County, Texas. “A defendant’s right to be sued in his home county is a valuable right which can
be defeated only by the clear establishment of a specific statutory exception to that right.” Hunt v.
Handerson, Clayton & Co., 574 S.W.2d 826, 830 (Tex. Civ. App. – Amarillo 1978, no writ),citing,
B & C Construction Co. v. Grain Handling Corp., 521 S.W.2d 98, 101 (Tex.Civ. App. Amarillo
1975, no writ). There is no statutory exception preventing this matter from proceeding in Fort
Bend County.
Pearland was joined in this suit solely in an effort to confer jurisdiction in Harris
County, Texas. See generally, Texas-Louisiana Power Co. v. Wells, 121 Tex. 397, 48 S.W.2d 978,
981 (1932)(“such plea of privilege would be insufficient as a matter of law to question the venue
of such suit in Montague County because it wholly fails to allege that the defendant Terrall Toll
Bridge Company is an improper defendant or in any manner joined as such in a fraudulent manner
so as to confer jurisdiction in Montague County…”). Pearland is an improper defendant.
The Minor Plaintiff’s alleged injuries occurred at the Sugar Land Urban Air
located at 9848 US-90 ALT, Sugar Land, TX 77478 (“the Sugar Land Park”). The Fort Bend
County Central Appraisal District list the tenant as Sugar Land and the owner as Zoya Enterprises
(located in Sugar Land, Texas). Despite real property records clearly identifying the owner and
tenant of the Sugar Land Park, Plaintiffs falsely claim that Pearland owns, operates, manages,
markets, directs and controls the premises. “When a venue fact is specifically denied, the party
pleading the venue fact must make prima facie proof of it.” Maranatha Temple, Inc. v. Enterprise
DEFENDANTS SUGAR LAND URBAN AIR, LLC; PEARLAND URBAN AIR, LLC; UATP
MANAGEMENT, LLC; UATP HOLDINGS, LLC’S MOTION TO TRANSFER VENUE AGE
Products Co., 833 S.W.2d 736, 740 (Tex. App. – Houston [1 Dist.] 1992, writ denied.). Plaintiff’s
cannot satisfy this prima facie proof.
Moreover, “[i]f a defendant objects to the plaintiff’s venue choice and properly
challenges that choice through a motion to transfer venue, the question of proper venue is raised.”
Wilson v. Texas Parks and Wildlife Dept., 886 S.W.2d 259, 260 (Tex. 1994). “The burden is on
the plaintiff to prove that venue is maintainable in the county of suit.” Id. If the plaintiff “fails to
meet this burden, the trial court must transfer the lawsuit to another specified county of proper
venue.” Id.
Consistent with the foregoing, Plaintiffs need to show that Pearland owns, controls,
directs, markets. etc. the facility operated by Sugar Land at the Sugar Land Park. They cannot do
so. As a result, it is logical to conclude that Pearland was improperly joined in an effort to create
venue in Harris County, Texas, where venue otherwise does not exist.
C. ENUE IN ORT END OUNTY S ONVENIENT FOR LL ARTIES.
Pursuant to Tex. Civ. Prac. & Rem. Code § 15.002(b), for the convenience of the
parties and witnesses, and in the interest of justice, a court may transfer an action to a county of
proper venue if the Court finds:
Maintenance of the action in the county of suit would work an injustice to the
movant considering the movant’s economic and personal hardship;
b. The balance of interests of all the parties predominates in favor of the action being
brought in Fort Bend County; and
c. The transfer to Fort Bend County would not work an injustice to any other party.
16. The purpose of § 15.002(b) is to ensure that cases are tried where they “sensibly
belong[].” Garza v. Garcia, 137 S.W.3d 36, 40 (Tex. 2004).
DEFENDANTS SUGAR LAND URBAN AIR, LLC; PEARLAND URBAN AIR, LLC; UATP
MANAGEMENT, LLC; UATP HOLDINGS, LLC’S MOTION TO TRANSFER VENUE AGE
17. All of Sugar Land’s employees, witnesses and records are located in Fort Bend
County—not Harris County. See Affidavit of Aubrey Hall, attached hereto as Exhibit B.
Additionally, the operation of Sugar Land’s business is primarily in Fort Bend County. See id.
Plaintiffs reside in Fort Bend County, Texas. Plaintiffs’ Original Petition, ¶2. The balance of
interests of all the parties weighs in favor of the action being brought in Fort Bend County. Tex.
Civ. Prac. & Rem. Code § 15.002(b)(2).
Harris County is not a county of mandatory venue, and Fort Bend County is a
county of proper venue. See id. at § 15.002(b). Therefore, this Court should transfer this matter to
Fort Bend County, Texas.
III. PRAYER
For the reasons discussed above, Defendants request that this Court grant their Motion to
Transfer Venue and transfer this cause to the District Court of Fort Bend County, Texas, taxing
costs incurred herein against Plaintiffs, and grant all such other and further relief to which they
may show themselves justly entitled, whether at law or in equity.
DEFENDANTS SUGAR LAND URBAN AIR, LLC; PEARLAND URBAN AIR, LLC; UATP
MANAGEMENT, LLC; UATP HOLDINGS, LLC’S MOTION TO TRANSFER VENUE AGE
WOOD SMITH HENNING & BERMAN, LLP
/s/ Christopher K. Chapaneri
Robert W. Hellner, State Bar No. 24108154
Christopher K. Chapaneri, State Bar No. 24065032
Madison O. Arcemont, State Bar No. 24125486
14860 Landmark Blvd., Suite 120
Dallas, Texas 75254
Telephone: (469) 210-2050
Fax: (469) 210-2051
rhellner@wshblaw.com
cchapaneri@wshblaw.com
marcemont@wshblaw.com
ATTORNEYS FOR DEFENDANTS
SUGAR LAND URBAN AIR, LLC
PEARLAND URBAN AIR, LLC, UATP
MANAGEMENT, LLC, UATP HOLDINGS, LLC
DEFENDANTS SUGAR LAND URBAN AIR, LLC; PEARLAND URBAN AIR, LLC; UATP
MANAGEMENT, LLC; UATP HOLDINGS, LLC’S MOTION TO TRANSFER VENUE AGE
CERTIFICATE OF SERVICE
I certify that on July 6, 2022, a copy of Defendants Sugar Land Urban Air, LLC; Pearland
Urban Air, LLC; UATP Management, LLC; UATP Holdings, LLC’s Motion To Transfer Venue
was served on all parties by electronic service, and the electronic transmission was reported as
complete. My email address is cchapaneri@wshblaw.com.
Jason A. Gibson
Casey L. Gibson
The Gibson Law Firm
3701 Kirby Drive, Suite 101
Houston, Texas 77098
jag@jag-lawfirm.com
cgibson@jag-lawfirm.com
Attorneys for Plaintiff
/s/Christopher K. Chapaneri
Christopher K. Chapaneri
DEFENDANTS SUGAR LAND URBAN AIR, LLC; PEARLAND URBAN AIR, LLC; UATP
MANAGEMENT, LLC; UATP HOLDINGS, LLC’S MOTION TO TRANSFER VENUE AGE
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CAUSE NO. 202233408 AMANEH SANAA ISPAHANY, IN THE DISTRICT COURT OF Individually, and as Next Friend of A.J. (Minor) Plaintiff, HARRIS COUNTY, TEXAS SUGAR LAND URBAN AIR, LLC, PEARLAND URBAN AIR, LLC, UATP MANAGEMENT, LLC UATP HOLDINGS, LLC & ROCKWOOD ALLIANCES, INC. D/B/A ROCKWOOD BUILDERS Defendants. TH JUDICIAL DISTRICT DEFENDANTS SUGAR LAND URBAN AIR, LLC; PEARLAND URBAN AIR, LLC; UATP MANAGEMENT, LLC; AND UATP HOLDINGS, LLC’S MOTION TO TRANSFER VENUE NOW COME Defendants Sugar Land Urban Air, LLC (“Sugar Land”), Pearland Urban Air, LLC (“Pearland”), UATP Management, LLC (“UATP Management”), and UATP Holdings, LLC’s (“UATP Holdings”), and file their Motion to Transfer Venue pursuant to Texas Rules of Civil Procedure 86 and Texas Civil Practice and Remedies Code, § 15.002(b), asking this Court to transfer venue of this cause from Harris County, Texas to Fort Bend County, Texas, since the events giving rise to Plaintiffs’ Petition took place in Fort Bend County, Texas. In addition, a contract governing waiver, release, and arbitration of the claims alleged by Plaintiffs mandates venue is properly Fort Bend County, Texas. Plaintiffs improperly joined Pearland in this action in an effort to proceed in an improper venue. In support thereof, Defendants respectfully state as follows: DEFENDANTS SUGAR LAND URBAN AIR, LLC; PEARLAND URBAN AIR, LLC; UATP MANAGEMENT, LLC; UATP HOLDINGS, LLC’S MOTION TO TRANSFER VENUE AGE I. FACTUAL BACKGROUND Plaintiffs Amaneh Sanaa Ispahany and minor plaintiff A.J, (hereinafter “Minor Plaintiff”), upon information and belief, are residents of Fort Bend County, Texas and brought this lawsuit against Defendants as the result of a June 4, 2022 incident that allegedly occurred at the Urban Air Trampoline Park located at 9848 US-90 ALT, Sugar Land, Texas 77487. See Plaintiffs’ Original Petition. This incident occurred in Fort Bend County, where Sugar Land operates and has its principal place of business. Plaintiffs allege negligence, premises liability, negligence per se, and negligent misrepresentation causes of action against all Defendants. Plaintiffs allege that venue in Harris County is proper, based on the assertion that Defendants Pearland and Rockwood Alliances, Inc. have principal offices in Harris County. See Plaintiffs’ Original Petition Pearland is improperly named in this litigation. Therefore, venue cannot rely on Pearland’s principal offices. II. ARGUMENT AND AUTHORITY 5. In the interest of justice and for the convenience of the parties and witnesses, this matter should be transferred to Fort Bend County, pursuant to Tex. Civ. Prac. & Rem. Code § 15.002(b). The accident at issue occurred in Fort Bend County and Sugar Land and its principal member reside in Fort Bend County. In addition, most of the anticipated witnesses, including Plaintiffs, live in Fort Bend County. Moreover, there is contractual agreement governing the allegations here, which mandates this dispute should proceed in Fort Bend County. A. ERMISSIVE ENUE RUMPS ENERAL ENUE ULES. Tex. Civ. Prac. & Rem. Code § 15.035 provides that permissive venue exists if a person has contracted in writing to perform an obligation in a particular county and expressly DEFENDANTS SUGAR LAND URBAN AIR, LLC; PEARLAND URBAN AIR, LLC; UATP MANAGEMENT, LLC; UATP HOLDINGS, LLC’S MOTION TO TRANSFER VENUE AGE names the county or a definite place in that county. The reported legal guardian of Minor Plaintiff executed a Release and Indemnification Agreement (“Agreement”) for Sugar Land which: (1) contains an arbitration agreement (which Sugar Land does not waive) and (2) provides that “[v]enue for any action brought hereunder or due to Participant’s use of the Premises or participation in the Activities shall lie in the County in which the Premises is located.” See Agreement, attached hereto as Exhibit “A.” Here, “the County in which the Premises is located” is Fort Bend County. Plaintiffs allege personal injuries at a trampoline park located at 9848 US-90 ALT, Sugar Land, TX 77478. This is physically located in Fort Bend County, Texas. The Agreement expressly states that the activities governed by the Agreement may occur in, about, or near 9848 Hwy 90A, Sugar Land, TX 77478. Exhibit A, ¶ 9. Therefore, Fort Bend County, Texas is the proper venue. “If no mandatory provision applies, the permissive venue provision allows suits involving specific types of claims to be brought in certain counties [citations omitted]. If no mandatory or permissive venue provision governs the claim at issue, the general rules will apply.” Scott Law Offices v. Quinney Holdings, LLC, No. 01-19-00739-CV, 2020 WL 4006438, at *3 (Tex. App.—Houston [1st Dist.] July 16, 2020, no pet.). Because there is a permissive venue applicable to the claims at issue in this lawsuit, as stated by the Agreement, the Court should transfer this lawsuit to Fort Bend County, Texas. B. PECIFIC ENIAL OF ENUE UE TO RAUDULENT OINDER OF ARTY 9. In addition, Tex. Civ. Prac. & Rem. Code § 15.002(a)(1) states that a lawsuit shall be brought in the county in which all or a substantial part of the events or omissions giving rise to Sugarland will move to compel arbitration once the Court issues it’s ruling on the motion to transfer venue. DEFENDANTS SUGAR LAND URBAN AIR, LLC; PEARLAND URBAN AIR, LLC; UATP MANAGEMENT, LLC; UATP HOLDINGS, LLC’S MOTION TO TRANSFER VENUE AGE the claim occurred. Here, the events or omissions giving rise to this lawsuit occurred in Fort Bend County Texas at the Sugar Land premises. Moreover, § 15.002(a)(3) provides that venue is proper in the county of the defendant’s principal office in Texas. Sugar Land maintains its principal office in Fort Bend County, Texas. “A defendant’s right to be sued in his home county is a valuable right which can be defeated only by the clear establishment of a specific statutory exception to that right.” Hunt v. Handerson, Clayton & Co., 574 S.W.2d 826, 830 (Tex. Civ. App. – Amarillo 1978, no writ),citing, B & C Construction Co. v. Grain Handling Corp., 521 S.W.2d 98, 101 (Tex.Civ. App. Amarillo 1975, no writ). There is no statutory exception preventing this matter from proceeding in Fort Bend County. Pearland was joined in this suit solely in an effort to confer jurisdiction in Harris County, Texas. See generally, Texas-Louisiana Power Co. v. Wells, 121 Tex. 397, 48 S.W.2d 978, 981 (1932)(“such plea of privilege would be insufficient as a matter of law to question the venue of such suit in Montague County because it wholly fails to allege that the defendant Terrall Toll Bridge Company is an improper defendant or in any manner joined as such in a fraudulent manner so as to confer jurisdiction in Montague County…”). Pearland is an improper defendant. The Minor Plaintiff’s alleged injuries occurred at the Sugar Land Urban Air located at 9848 US-90 ALT, Sugar Land, TX 77478 (“the Sugar Land Park”). The Fort Bend County Central Appraisal District list the tenant as Sugar Land and the owner as Zoya Enterprises (located in Sugar Land, Texas). Despite real property records clearly identifying the owner and tenant of the Sugar Land Park, Plaintiffs falsely claim that Pearland owns, operates, manages, markets, directs and controls the premises. “When a venue fact is specifically denied, the party pleading the venue fact must make prima facie proof of it.” Maranatha Temple, Inc. v. Enterprise DEFENDANTS SUGAR LAND URBAN AIR, LLC; PEARLAND URBAN AIR, LLC; UATP MANAGEMENT, LLC; UATP HOLDINGS, LLC’S MOTION TO TRANSFER VENUE AGE Products Co., 833 S.W.2d 736, 740 (Tex. App. – Houston [1 Dist.] 1992, writ denied.). Plaintiff’s cannot satisfy this prima facie proof. Moreover, “[i]f a defendant objects to the plaintiff’s venue choice and properly challenges that choice through a motion to transfer venue, the question of proper venue is raised.” Wilson v. Texas Parks and Wildlife Dept., 886 S.W.2d 259, 260 (Tex. 1994). “The burden is on the plaintiff to prove that venue is maintainable in the county of suit.” Id. If the plaintiff “fails to meet this burden, the trial court must transfer the lawsuit to another specified county of proper venue.” Id. Consistent with the foregoing, Plaintiffs need to show that Pearland owns, controls, directs, markets. etc. the facility operated by Sugar Land at the Sugar Land Park. They cannot do so. As a result, it is logical to conclude that Pearland was improperly joined in an effort to create venue in Harris County, Texas, where venue otherwise does not exist. C. ENUE IN ORT END OUNTY S ONVENIENT FOR LL ARTIES. Pursuant to Tex. Civ. Prac. & Rem. Code § 15.002(b), for the convenience of the parties and witnesses, and in the interest of justice, a court may transfer an action to a county of proper venue if the Court finds: Maintenance of the action in the county of suit would work an injustice to the movant considering the movant’s economic and personal hardship; b. The balance of interests of all the parties predominates in favor of the action being brought in Fort Bend County; and c. The transfer to Fort Bend County would not work an injustice to any other party. 16. The purpose of § 15.002(b) is to ensure that cases are tried where they “sensibly belong[].” Garza v. Garcia, 137 S.W.3d 36, 40 (Tex. 2004). DEFENDANTS SUGAR LAND URBAN AIR, LLC; PEARLAND URBAN AIR, LLC; UATP MANAGEMENT, LLC; UATP HOLDINGS, LLC’S MOTION TO TRANSFER VENUE AGE 17. All of Sugar Land’s employees, witnesses and records are located in Fort Bend County—not Harris County. See Affidavit of Aubrey Hall, attached hereto as Exhibit B. Additionally, the operation of Sugar Land’s business is primarily in Fort Bend County. See id. Plaintiffs reside in Fort Bend County, Texas. Plaintiffs’ Original Petition, ¶2. The balance of interests of all the parties weighs in favor of the action being brought in Fort Bend County. Tex. Civ. Prac. & Rem. Code § 15.002(b)(2). Harris County is not a county of mandatory venue, and Fort Bend County is a county of proper venue. See id. at § 15.002(b). Therefore, this Court should transfer this matter to Fort Bend County, Texas. III. PRAYER For the reasons discussed above, Defendants request that this Court grant their Motion to Transfer Venue and transfer this cause to the District Court of Fort Bend County, Texas, taxing costs incurred herein against Plaintiffs, and grant all such other and further relief to which they may show themselves justly entitled, whether at law or in equity. DEFENDANTS SUGAR LAND URBAN AIR, LLC; PEARLAND URBAN AIR, LLC; UATP MANAGEMENT, LLC; UATP HOLDINGS, LLC’S MOTION TO TRANSFER VENUE AGE WOOD SMITH HENNING & BERMAN, LLP /s/ Christopher K. Chapaneri Robert W. Hellner, State Bar No. 24108154 Christopher K. Chapaneri, State Bar No. 24065032 Madison O. Arcemont, State Bar No. 24125486 14860 Landmark Blvd., Suite 120 Dallas, Texas 75254 Telephone: (469) 210-2050 Fax: (469) 210-2051 rhellner@wshblaw.com cchapaneri@wshblaw.com marcemont@wshblaw.com ATTORNEYS FOR DEFENDANTS SUGAR LAND URBAN AIR, LLC PEARLAND URBAN AIR, LLC, UATP MANAGEMENT, LLC, UATP HOLDINGS, LLC DEFENDANTS SUGAR LAND URBAN AIR, LLC; PEARLAND URBAN AIR, LLC; UATP MANAGEMENT, LLC; UATP HOLDINGS, LLC’S MOTION TO TRANSFER VENUE AGE CERTIFICATE OF SERVICE I certify that on July 6, 2022, a copy of Defendants Sugar Land Urban Air, LLC; Pearland Urban Air, LLC; UATP Management, LLC; UATP Holdings, LLC’s Motion To Transfer Venue was served on all parties by electronic service, and the electronic transmission was reported as complete. My email address is cchapaneri@wshblaw.com. Jason A. Gibson Casey L. Gibson The Gibson Law Firm 3701 Kirby Drive, Suite 101 Houston, Texas 77098 jag@jag-lawfirm.com cgibson@jag-lawfirm.com Attorneys for Plaintiff /s/Christopher K. Chapaneri Christopher K. Chapaneri DEFENDANTS SUGAR LAND URBAN AIR, LLC; PEARLAND URBAN AIR, LLC; UATP MANAGEMENT, LLC; UATP HOLDINGS, LLC’S MOTION TO TRANSFER VENUE AGE