Preview
Electronically Filed
9/21/2022 8:45 PM
Hidalgo County District Clerks
Reviewed By: Jose C. Hernandez
CAUSE NO. C-2828-19-G
CALI WOOD WEATHERREAD § IN THE DISTRICT COURT
Individually, as Representative §
of the Estate of WILLIAM ADELL, §
WEATHERREAD, II, Deceased, and as §
Next Friend of IAN GUNNER WEATHERREAD, §
ERIK MATTHEW WEATHERREAD, §
IZIAK TRENT WEATHERREAD, §
AND MEGAN ANN MARIE WEATHERREAD, §
Minors, and DEBRA HUSBAND § 370TH JUDICIAL DISTRICT
Plaintiffs, §
§
vs. §
§
HUGO ALEJANDRO CABRERA, §
NTACT OPERATIONS, LLC AND NTACT §
CONSTRUCTORS, LTD. §
Defendants § HIDALGO COUNTY, TEXAS
DEFENDANTS NTACT OPERATIONS, LLC AND NTACT CONSTRUCTORS, LTD.’S
MOTION TO EQUALIZE PEREMPTORY STRIKES
TO THE HONORABLE JUDGE OF SAID COURT:
COME NOW NTACT OPERATIONS, LLC and NTACT CONSTRUCTORS, LTD.,
two Defendants in the above-entitled and numbered cause, and pursuant to Rule 233 of
the Texas Rules of Civil Procedure, file this their Motion to Equalize Peremptory Strikes,
and for such motion would respectfully show unto this Court the following:
I.
BRIEF BACKGROUND
On or about June 5, 2019, on Texas State Highway 128 approaching the New
Mexico border, a fatal two vehicle accident occurred between a vehicle being driven by
Defendant Hugo Alejandro Cabrera and a vehicle being driven by Plaintiff William Adell
Weatherread, II, deceased. Defendant Cabrera is alleged to have caused the accident in
question, which resulted in the death of William Adell Weatherread, II, Deceased. It is also
Electronically Filed
9/21/2022 8:45 PM
Hidalgo County District Clerks
Reviewed By: Jose C. Hernandez
alleged that Defendant Cabrera was in the course and scope of his employment with these
Defendants, which these Defendants strenuously deny. Defendant Cabrera also takes the
position that he was in the course and scope of his employment with Defendant NTACT.
II.
APPLICABLE RULE
Rule 233 of the Texas Rules of Civil Procedures states, in pertinent part, as follows:
Motion to Equalize. In multiple party cases, upon motion of any litigant
made prior to the exercise of peremptory challenges, it shall be the duty of
the trial judge to equalize the number of peremptory challenges so that no
litigant or side is given unfair advantage as a result of the alignment of the
litigants and the award of peremptory challenges to each litigant or side. In
determining how the challenges should be allocated the court shall consider
any mattaer brought to the attention of the trial judge concerning the ends of
justice and the elimination of an unfair advantage.
III.
ARGUMENT
Defendants NTACT OPERATIONS, LLC and NTACT CONSTRUCTORS, LTD.
would respectfully show this Court that Plaintiffs and Defendant Hugo Alejandro Cabrera
are one hundred percent (100%) aligned, as the Plaintiffs and Defendant Cabrera share
the common interest of arguing and attempting to prove that Defendant Cabrera was in the
course and scope of his employment with Defendants NTACT OPERATIONS, LLC and
NTACT CONSTRUCTORS, LTD. at the time of the accident made the basis of this lawsuit.
The most critical and dispositive issue in this case is the issue of whether Cabrera was in
the course and scope of his employment at the time of the accident in question.
DEFENDANTS NTACT OPERATIONS, LLC AND NTACT CONSTRUCTORS, LTD.’S MOTION TO EQUALIZE PEREMPTORY STRIKES - PAGE 2 OF 5
Electronically Filed
9/21/2022 8:45 PM
Hidalgo County District Clerks
Reviewed By: Jose C. Hernandez
Accordingly, the allocation of peremptory challenges among the parties in this case
should reflect the common interests existing between Plaintiffs and Defendant Hugo
Alejandro Cabrera.
IV.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Defendants NTACT OPERATIONS,
LLC and NTACT CONSTRUCTORS, LTD. pray that upon hearing hereof, this Court grant
their motion to equalize the number of peremptory challenges; that Plaintiffs and Defendant
Cabrera are awarded three peremptory strikes each and Defendants NTACT be awarded
six peremptory strikes; or some other number which would fairly equalize the strikes
awarded; and for such other and further relief, either at law or in equity, to which these
Defendants may be justly entitled to receive.
Respectfully submitted,
David L. Ortega
State Bar No. 00791377
Stephen D. Navarro
State Bar No. 00792712
Naman Howell Smith & Lee, PLLC
10001 Reunion Place, Suite 600
San Antonio, Texas 78216
Telephone No.: (210) 731-6415
Telecopier No.: (210) 971-6959
E-Mail: dortega@namanhowell.com
snavarro@namanhowell.com
DEFENDANTS NTACT OPERATIONS, LLC AND NTACT CONSTRUCTORS, LTD.’S MOTION TO EQUALIZE PEREMPTORY STRIKES - PAGE 3 OF 5
Electronically Filed
9/21/2022 8:45 PM
Hidalgo County District Clerks
Reviewed By: Jose C. Hernandez
Natasha N. Taylor
State Bar No. 24071117
Lisa M. Wright
State Bar No. 24089367
Wright Close & Barger, LLP
One Riverway, Suite 2200
Houston, Texas 77056
Telephone No.: (713) 572-4321
Telecopier No.: (713) 572-4320
E-Mail: taylor@wrightclosebarger.com
lwright@wrightclosebarger.com
HOLE & ALVAREZ, L.L.P.
P. O. Box 720547
McAllen, Texas 78504-0547
Telephone No.: (956) 631-2891
Telecopier No.: (956) 631-2415
E-Mail: Mail@holealvarez.com
By: /s/ Ronald G. Hole
Ronald G. Hole
State Bar No. 09834200
ATTORNEYS FOR DEFENDANTS
NTACT OPERATIONS, LLC and
NTACT CONSTRUCTORS, LTD.
CERTIFICATE OF SERVICE
I, Ronald G. Hole, hereby certify that a true and correct copy of the above Defendants
NTACT Operations, LLC and NTACT Constructors, Ltd.’s Motion to Equalize Peremptory Strikes
has, on this 21st day of September 2022, been served via electronic transfer through an online
filing service, to the following counsel of record:
Attorneys for Plaintiffs
Mikal C. Watts
Francisco Guerra, IV
Watts Guerra, LLP
Four Dominion Drive
Bldg. 3, Suite 100
San Antonio, Texas 78257
E-Mail: mcwatts@wattsguerra.com
fguerra@wattsguerra.com
DEFENDANTS NTACT OPERATIONS, LLC AND NTACT CONSTRUCTORS, LTD.’S MOTION TO EQUALIZE PEREMPTORY STRIKES - PAGE 4 OF 5
Electronically Filed
9/21/2022 8:45 PM
Hidalgo County District Clerks
Reviewed By: Jose C. Hernandez
Mr. Tim Newsom
Law Offices of Frank L. Branson, P.C.
Highland Park Place
4514 Cole Avenue, 18th Floor
Dallas, Texas 75205
E-Mail: tnewsom@flbranson.com
James S. Shelton
Law Office of James S. Shelton
222 S. Sully
P. O. Box 1370
Clarendon, Texas 79226
E-Mail: james@sheltonlawyers.com
Attorneys for Co-Defendant
Hugo Alejandro Cabrera
Michael I. Ramirez
Joshua L. Nicholls
McCoy Leavitt Laskey, LLC
20726 Stone Oak Parkway, Suite 116
San Antonio, Texas 78258
E-Mail: mramirez@mlllaw.com
jnicholls@mlllaw.com
/s/ Ronald G. Hole
Ronald G. Hole
O P V :W E A -N T A \P L D
DEFENDANTS NTACT OPERATIONS, LLC AND NTACT CONSTRUCTORS, LTD.’S MOTION TO EQUALIZE PEREMPTORY STRIKES - PAGE 5 OF 5
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Ronald Hole on behalf of Ronald Hole
Bar No. 9834200
Ron@HoleAlvarez.com
Envelope ID: 68499403
Status as of 9/22/2022 3:08 PM CST
Associated Case Party: NTACT CONSTRUCTORS, LTD
Name BarNumber Email TimestampSubmitted Status
Orfie Vela Orfie@HoleAlvarez.com 9/21/2022 8:45:41 PM SENT
Natasha N.Taylor taylor@wrightclosebarger.com 9/21/2022 8:45:41 PM SENT
Lisa M.Wright lwright@wrightclosebarger.com 9/21/2022 8:45:41 PM SENT
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Ronald Hole on behalf of Ronald Hole
Bar No. 9834200
Ron@HoleAlvarez.com
Envelope ID: 68499403
Status as of 9/22/2022 3:08 PM CST
Associated Case Party: CALIWOODWEATHERREAD
Name BarNumber Email TimestampSubmitted Status
Mikal CWatts mcwatts@wattsguerra.com 9/21/2022 8:45:41 PM SENT
Francisco Guerra IV fguerra@wattsguerra.com 9/21/2022 8:45:41 PM SENT
Mark A. J.Fassold mfassold@wattsguerra.com 9/21/2022 8:45:41 PM SENT
WATTS GUERRA mcwatts@wattsguerra.com 9/21/2022 8:45:41 PM SENT
WATTS GUERRA fguerra@wattsguerra.com 9/21/2022 8:45:41 PM SENT
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Ronald Hole on behalf of Ronald Hole
Bar No. 9834200
Ron@HoleAlvarez.com
Envelope ID: 68499403
Status as of 9/22/2022 3:08 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Watts Guerra LLP service-sa@wattsguerra.com 9/21/2022 8:45:41 PM SENT
David L.Ortega dortega@namanhowell.com 9/21/2022 8:45:41 PM SENT
James S.Shelton james@sheltonlawyers.com 9/21/2022 8:45:41 PM SENT
Audrey JSimon audrey@youngfirm.com 9/21/2022 8:45:41 PM SENT
Joshua LNicholls jnicholls@mlllaw.com 9/21/2022 8:45:41 PM SENT
Kandice Melendez kmelendez@wattsguerra.com 9/21/2022 8:45:41 PM SENT
Amanda Osborne aosborne@wattsguerra.com 9/21/2022 8:45:41 PM SENT
Terri Harrison terri@youngfirm.com 9/21/2022 8:45:41 PM SENT
STEPHEN NAVARRO SNAVARRO@NAMANHOWELL.COM 9/21/2022 8:45:41 PM SENT
RONALD G.HOLE MAIL@HOLEALVAREZ.COM 9/21/2022 8:45:41 PM SENT
Alexis R.Garcia argarcia@wattsguerra.com 9/21/2022 8:45:41 PM SENT
TIM NEWSOM TNEWSOM@FLBRANSON.COM 9/21/2022 8:45:41 PM SENT
TIM NEWSOM EFILETN@FLBRANSON.COM 9/21/2022 8:45:41 PM SENT
FRANK BRANSON FLBRANSON@FLBRANSON.COM 9/21/2022 8:45:41 PM SENT
MICHAEL RAMIREZ MRAMIREZ@MLLLAW.COM 9/21/2022 8:45:41 PM SENT
Ashley Nichols anichols@namanhowell.com 9/21/2022 8:45:41 PM SENT
Tim Newsome tim@youngfirm.com 9/21/2022 8:45:41 PM ERROR
Ronald G.Hole ron@holealvarez.com 9/21/2022 8:45:41 PM SENT
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Ronald Hole on behalf of Ronald Hole
Bar No. 9834200
Ron@HoleAlvarez.com
Envelope ID: 68499403
Status as of 9/22/2022 3:08 PM CST
Associated Case Party: HUGOALEJANDROCABRERA
Name BarNumber Email TimestampSubmitted Status
Michael IRamirez mramirez@mlllaw.com 9/21/2022 8:45:41 PM SENT
Victoria Ford vford@mlllaw.com 9/21/2022 8:45:41 PM SENT
Joshua L.Nicholls jnicholls@mlllaw.com 9/21/2022 8:45:41 PM SENT
Preview
Electronically Filed 9/21/2022 8:45 PM Hidalgo County District Clerks Reviewed By: Jose C. Hernandez CAUSE NO. C-2828-19-G CALI WOOD WEATHERREAD § IN THE DISTRICT COURT Individually, as Representative § of the Estate of WILLIAM ADELL, § WEATHERREAD, II, Deceased, and as § Next Friend of IAN GUNNER WEATHERREAD, § ERIK MATTHEW WEATHERREAD, § IZIAK TRENT WEATHERREAD, § AND MEGAN ANN MARIE WEATHERREAD, § Minors, and DEBRA HUSBAND § 370TH JUDICIAL DISTRICT Plaintiffs, § § vs. § § HUGO ALEJANDRO CABRERA, § NTACT OPERATIONS, LLC AND NTACT § CONSTRUCTORS, LTD. § Defendants § HIDALGO COUNTY, TEXAS DEFENDANTS NTACT OPERATIONS, LLC AND NTACT CONSTRUCTORS, LTD.’S MOTION TO EQUALIZE PEREMPTORY STRIKES TO THE HONORABLE JUDGE OF SAID COURT: COME NOW NTACT OPERATIONS, LLC and NTACT CONSTRUCTORS, LTD., two Defendants in the above-entitled and numbered cause, and pursuant to Rule 233 of the Texas Rules of Civil Procedure, file this their Motion to Equalize Peremptory Strikes, and for such motion would respectfully show unto this Court the following: I. BRIEF BACKGROUND On or about June 5, 2019, on Texas State Highway 128 approaching the New Mexico border, a fatal two vehicle accident occurred between a vehicle being driven by Defendant Hugo Alejandro Cabrera and a vehicle being driven by Plaintiff William Adell Weatherread, II, deceased. Defendant Cabrera is alleged to have caused the accident in question, which resulted in the death of William Adell Weatherread, II, Deceased. It is also Electronically Filed 9/21/2022 8:45 PM Hidalgo County District Clerks Reviewed By: Jose C. Hernandez alleged that Defendant Cabrera was in the course and scope of his employment with these Defendants, which these Defendants strenuously deny. Defendant Cabrera also takes the position that he was in the course and scope of his employment with Defendant NTACT. II. APPLICABLE RULE Rule 233 of the Texas Rules of Civil Procedures states, in pertinent part, as follows: Motion to Equalize. In multiple party cases, upon motion of any litigant made prior to the exercise of peremptory challenges, it shall be the duty of the trial judge to equalize the number of peremptory challenges so that no litigant or side is given unfair advantage as a result of the alignment of the litigants and the award of peremptory challenges to each litigant or side. In determining how the challenges should be allocated the court shall consider any mattaer brought to the attention of the trial judge concerning the ends of justice and the elimination of an unfair advantage. III. ARGUMENT Defendants NTACT OPERATIONS, LLC and NTACT CONSTRUCTORS, LTD. would respectfully show this Court that Plaintiffs and Defendant Hugo Alejandro Cabrera are one hundred percent (100%) aligned, as the Plaintiffs and Defendant Cabrera share the common interest of arguing and attempting to prove that Defendant Cabrera was in the course and scope of his employment with Defendants NTACT OPERATIONS, LLC and NTACT CONSTRUCTORS, LTD. at the time of the accident made the basis of this lawsuit. The most critical and dispositive issue in this case is the issue of whether Cabrera was in the course and scope of his employment at the time of the accident in question. DEFENDANTS NTACT OPERATIONS, LLC AND NTACT CONSTRUCTORS, LTD.’S MOTION TO EQUALIZE PEREMPTORY STRIKES - PAGE 2 OF 5 Electronically Filed 9/21/2022 8:45 PM Hidalgo County District Clerks Reviewed By: Jose C. Hernandez Accordingly, the allocation of peremptory challenges among the parties in this case should reflect the common interests existing between Plaintiffs and Defendant Hugo Alejandro Cabrera. IV. PRAYER WHEREFORE, PREMISES CONSIDERED, Defendants NTACT OPERATIONS, LLC and NTACT CONSTRUCTORS, LTD. pray that upon hearing hereof, this Court grant their motion to equalize the number of peremptory challenges; that Plaintiffs and Defendant Cabrera are awarded three peremptory strikes each and Defendants NTACT be awarded six peremptory strikes; or some other number which would fairly equalize the strikes awarded; and for such other and further relief, either at law or in equity, to which these Defendants may be justly entitled to receive. Respectfully submitted, David L. Ortega State Bar No. 00791377 Stephen D. Navarro State Bar No. 00792712 Naman Howell Smith & Lee, PLLC 10001 Reunion Place, Suite 600 San Antonio, Texas 78216 Telephone No.: (210) 731-6415 Telecopier No.: (210) 971-6959 E-Mail: dortega@namanhowell.com snavarro@namanhowell.com DEFENDANTS NTACT OPERATIONS, LLC AND NTACT CONSTRUCTORS, LTD.’S MOTION TO EQUALIZE PEREMPTORY STRIKES - PAGE 3 OF 5 Electronically Filed 9/21/2022 8:45 PM Hidalgo County District Clerks Reviewed By: Jose C. Hernandez Natasha N. Taylor State Bar No. 24071117 Lisa M. Wright State Bar No. 24089367 Wright Close & Barger, LLP One Riverway, Suite 2200 Houston, Texas 77056 Telephone No.: (713) 572-4321 Telecopier No.: (713) 572-4320 E-Mail: taylor@wrightclosebarger.com lwright@wrightclosebarger.com HOLE & ALVAREZ, L.L.P. P. O. Box 720547 McAllen, Texas 78504-0547 Telephone No.: (956) 631-2891 Telecopier No.: (956) 631-2415 E-Mail: Mail@holealvarez.com By: /s/ Ronald G. Hole Ronald G. Hole State Bar No. 09834200 ATTORNEYS FOR DEFENDANTS NTACT OPERATIONS, LLC and NTACT CONSTRUCTORS, LTD. CERTIFICATE OF SERVICE I, Ronald G. Hole, hereby certify that a true and correct copy of the above Defendants NTACT Operations, LLC and NTACT Constructors, Ltd.’s Motion to Equalize Peremptory Strikes has, on this 21st day of September 2022, been served via electronic transfer through an online filing service, to the following counsel of record: Attorneys for Plaintiffs Mikal C. Watts Francisco Guerra, IV Watts Guerra, LLP Four Dominion Drive Bldg. 3, Suite 100 San Antonio, Texas 78257 E-Mail: mcwatts@wattsguerra.com fguerra@wattsguerra.com DEFENDANTS NTACT OPERATIONS, LLC AND NTACT CONSTRUCTORS, LTD.’S MOTION TO EQUALIZE PEREMPTORY STRIKES - PAGE 4 OF 5 Electronically Filed 9/21/2022 8:45 PM Hidalgo County District Clerks Reviewed By: Jose C. Hernandez Mr. Tim Newsom Law Offices of Frank L. Branson, P.C. Highland Park Place 4514 Cole Avenue, 18th Floor Dallas, Texas 75205 E-Mail: tnewsom@flbranson.com James S. Shelton Law Office of James S. Shelton 222 S. Sully P. O. Box 1370 Clarendon, Texas 79226 E-Mail: james@sheltonlawyers.com Attorneys for Co-Defendant Hugo Alejandro Cabrera Michael I. Ramirez Joshua L. Nicholls McCoy Leavitt Laskey, LLC 20726 Stone Oak Parkway, Suite 116 San Antonio, Texas 78258 E-Mail: mramirez@mlllaw.com jnicholls@mlllaw.com /s/ Ronald G. Hole Ronald G. Hole O P V :W E A -N T A \P L D DEFENDANTS NTACT OPERATIONS, LLC AND NTACT CONSTRUCTORS, LTD.’S MOTION TO EQUALIZE PEREMPTORY STRIKES - PAGE 5 OF 5 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Ronald Hole on behalf of Ronald Hole Bar No. 9834200 Ron@HoleAlvarez.com Envelope ID: 68499403 Status as of 9/22/2022 3:08 PM CST Associated Case Party: NTACT CONSTRUCTORS, LTD Name BarNumber Email TimestampSubmitted Status Orfie Vela Orfie@HoleAlvarez.com 9/21/2022 8:45:41 PM SENT Natasha N.Taylor taylor@wrightclosebarger.com 9/21/2022 8:45:41 PM SENT Lisa M.Wright lwright@wrightclosebarger.com 9/21/2022 8:45:41 PM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Ronald Hole on behalf of Ronald Hole Bar No. 9834200 Ron@HoleAlvarez.com Envelope ID: 68499403 Status as of 9/22/2022 3:08 PM CST Associated Case Party: CALIWOODWEATHERREAD Name BarNumber Email TimestampSubmitted Status Mikal CWatts mcwatts@wattsguerra.com 9/21/2022 8:45:41 PM SENT Francisco Guerra IV fguerra@wattsguerra.com 9/21/2022 8:45:41 PM SENT Mark A. J.Fassold mfassold@wattsguerra.com 9/21/2022 8:45:41 PM SENT WATTS GUERRA mcwatts@wattsguerra.com 9/21/2022 8:45:41 PM SENT WATTS GUERRA fguerra@wattsguerra.com 9/21/2022 8:45:41 PM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Ronald Hole on behalf of Ronald Hole Bar No. 9834200 Ron@HoleAlvarez.com Envelope ID: 68499403 Status as of 9/22/2022 3:08 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Watts Guerra LLP service-sa@wattsguerra.com 9/21/2022 8:45:41 PM SENT David L.Ortega dortega@namanhowell.com 9/21/2022 8:45:41 PM SENT James S.Shelton james@sheltonlawyers.com 9/21/2022 8:45:41 PM SENT Audrey JSimon audrey@youngfirm.com 9/21/2022 8:45:41 PM SENT Joshua LNicholls jnicholls@mlllaw.com 9/21/2022 8:45:41 PM SENT Kandice Melendez kmelendez@wattsguerra.com 9/21/2022 8:45:41 PM SENT Amanda Osborne aosborne@wattsguerra.com 9/21/2022 8:45:41 PM SENT Terri Harrison terri@youngfirm.com 9/21/2022 8:45:41 PM SENT STEPHEN NAVARRO SNAVARRO@NAMANHOWELL.COM 9/21/2022 8:45:41 PM SENT RONALD G.HOLE MAIL@HOLEALVAREZ.COM 9/21/2022 8:45:41 PM SENT Alexis R.Garcia argarcia@wattsguerra.com 9/21/2022 8:45:41 PM SENT TIM NEWSOM TNEWSOM@FLBRANSON.COM 9/21/2022 8:45:41 PM SENT TIM NEWSOM EFILETN@FLBRANSON.COM 9/21/2022 8:45:41 PM SENT FRANK BRANSON FLBRANSON@FLBRANSON.COM 9/21/2022 8:45:41 PM SENT MICHAEL RAMIREZ MRAMIREZ@MLLLAW.COM 9/21/2022 8:45:41 PM SENT Ashley Nichols anichols@namanhowell.com 9/21/2022 8:45:41 PM SENT Tim Newsome tim@youngfirm.com 9/21/2022 8:45:41 PM ERROR Ronald G.Hole ron@holealvarez.com 9/21/2022 8:45:41 PM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Ronald Hole on behalf of Ronald Hole Bar No. 9834200 Ron@HoleAlvarez.com Envelope ID: 68499403 Status as of 9/22/2022 3:08 PM CST Associated Case Party: HUGOALEJANDROCABRERA Name BarNumber Email TimestampSubmitted Status Michael IRamirez mramirez@mlllaw.com 9/21/2022 8:45:41 PM SENT Victoria Ford vford@mlllaw.com 9/21/2022 8:45:41 PM SENT Joshua L.Nicholls jnicholls@mlllaw.com 9/21/2022 8:45:41 PM SENT