Preview
FILED
3/14/2023 3:41 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Felicia Pitre DEPUTY
CAUSE NO. DC-23-02606
CHRISTOPHER S. WINN, ACTING INDIVIDUALLY IN THE DISTRICT COURT
AS THE PRIMARY BENEFICIARY OF THE SEREN
CAPITAL CHRISTOPHER S. WINN I998 DYNASTY
TRUST AND ACTING DERIVATIVELY ON BEHALF
OF THE TRUSTEE OF SUCH TRUST.
Plaintiff,
vs.
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TOLLESON PRIVATE BANK. ACTING
INDIVIDUALLY AND AS A (IO-TRUSTEE OF SUCH 298T“ JUDICIAL DISTRICT
TRUST. and STEPHEN T. WINN. ACTING
INDIVIDUALLY AND AS TRUSTEE OF THE SEREN
CAPITAL CHRISTOPHER S. WINN I998 DYNASTY
TRUST.
Defendants.
vs.
DAVID L. WINN AND CAROL WINN DUNAWAY.
Nominal Defendants.
DALLAS COUNTY, TEXAS
RETURN OF SERVICE
Came to my hand on Thursday, March 9, 2023 at 4:48 PM,
Executed at: 4143 MAPLE AVENUE, SUITE 400, DALLAS, TX 75219
at [:25 PM, on Friday, March 10, 2023,
by delivering to the within named:
STEVEN T. WIN N, ACTING AS CO-TRUSTEE OF THE 1998
DYNASTY TRUST by delivering to General Counsel, MEGAN SMALE
a true copy of this
CITATION and PLAINTIFF ’8 ORIGINAL PETITION
having first endorsed thereon the date of the delivery.
BEFORE ME. the undersigned authority. on this day personally appeared Adil Tadli who other being duly sworn on oath states: "My name is Adil
Tadli. am a person not less than eighteen (18} years of age and I am competent to make this oath. I am a resident of the State of Texas. I have
I
nor related or affiliated
personal knowledge of the facts and statements contained herein and aver that each is true and correct. I am not a party to
with any party to this suit. i have no interest in the outcome of the suit. I have never been convicted of a felony or of a misdemeanor involving moral
as they apply to service of
turpitude. I am familiar with the Texas Rules of Civil Procedure, and the Texas Civil Practice and Remedies Codes
and Justice
process. I am certified by the Judicial Branch Certification Commission to deliver citations and other notices from any District, County
Courts in and for the State of Texas in compliance with rule 103 and 50l.2 ol'thc TRCP.”
By''
2%”
\J'
AdII Tndli - PSC1206 - Exp (ISIJIIM
served@specialdelivery.eom
Subscribed and Sworn to by Adil Tadll, Before Me, the undersigned authority, on this [£16 day of March, 2023
"H
.plii
BRITTNEY LEIGH woooALL'
Notary Public ate of Texas
STATE OF TEXAS Notary Public In ad for the
IDMZQTQOZO-i'
Comm. Ex Saw 32.1
i.»
FORM NO. 353-3—CITATION
THE STATE OF TEXAS ESERVE
CITATION
To: STEVEN T. WINN, ACTING AS CO-TRUSTEE OF THE 1998 DYNASTY TRUST
4143 MAPLE AVENUE, SUITE 400
DALLAS, TEXAS 75219
GREETINGS:
You have been sued. You may employ an attorney. If you or your attorney do not file a written
CHRISTOPHER S WINN
answer with the clerk who issued this citation by 10 o'clock am. on the Monday next following the
_\_r_s.
expiration of twenty days after you were served this citation and ORIGINAL petition, a default TOLLESON PRIVATE BANE, et al
judgment may be taken against you. In addition to filing a written answer with the clerk, you may
be required to make initial disclosures to the other parties of this suit. These disclosures generally
must be made no later than 30 days after you file your answer with the clerk. Find out more at ISSUED
TexasLawHelp.org. Your answer should be addressed to the clerk of the 298th District Court at on this the 9th day of March, 2023
600 Commerce Street, Dallas, Texas 75202.
ACTING INDIVIDUALLY AS THE
Said Plaintiff being CHRISTOPHER S WINN, FELICIA PITRE
PRIMARY BENEFICIARY OF THE SEREN CAPITAL CHRISTOPHER S. WINN 1998 Clerk District Courts,
DYNASTY TRUST AND ACTING DERIVATIVELY ON BEHALF OF THE TRUSTEE OF Dallas County, Texas
SUCH TRUST
u
By: GAY LANE Deputy
Filed in said Court 24th day of February, 2023 against
Attorney for Plaintiff
TOLLESON PRIVATE BANK, ACTING INDIVIDUALLY AND AS A CO- TRUSTEE OF FRANK N IKARD
SUCH TRUST ; STEPHEN T WINN, ACTING INDIVIDUALLY AND AS TRUSTEE OF 400WEST 15TH ST
THE SEREN CAPITAL CHRISTOPHER S. WINN 1998 DYNASTY TRUST; DAVID L. SUITE 975
WINN; CAROL WIN N DUNAWAY, NOMINAL DEFENDANTS AUSTIN TX 7870]
512-472-2884
For Suit, said suit being numbered DC-23-02606, the nature of which demand is as follows: ikard®igilaw.com
Suit on OTHER (CIVIL) etc. as shown on said petition, a copy of which accompanies DALLAS COUNTY
this citation. If this citation is not served, it shall be returned unexecuted. SERVICE FEES
NOT PAID
WITNESS: FELICIA PITRE, Clerk of the District Courts of Dallas, County Texas.
Given under my hand and the Seal of said Court at office on this the 9th day of March, 2023
ATTEST: FELICIA PITRE,
Clerk of the District Courts of Dallas County, Texas
gull, ‘8
I
9‘ ,&
By 3 , Deputy 2,,
GAY LANE as “W‘s”!
OFFICER’S RETURN
Cause No. DC-23-02606
Court No.: 298th District Court
Style: CHRISTOPHER S WINN
VS.
TOLLESON PRIVATE BANK, ct al
Came to hand on the day of , 20 , at o'clock .M.
Executed at , within the County of at
o'clock .M. on the day of , 20 , by delivering to the within named
each, in person, a true copy of this Citation together with the accompanying copy of this pleading, having first endorsed on same date of
delivery. The distance actually traveled by me in serving such process was miles and my fees are as follows: To certify which
witness my hand.
For serving Citation $
For mileage $ of County,
For Notary $ By Deputy
(Must be verified if served outside the State of Texas.)
Signed and sworn to by the said before me this day of .
20 , to certify which witness my hand and seal of office.
Notary Public County
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FILED 3/14/2023 3:41 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Felicia Pitre DEPUTY CAUSE NO. DC-23-02606 CHRISTOPHER S. WINN, ACTING INDIVIDUALLY IN THE DISTRICT COURT AS THE PRIMARY BENEFICIARY OF THE SEREN CAPITAL CHRISTOPHER S. WINN I998 DYNASTY TRUST AND ACTING DERIVATIVELY ON BEHALF OF THE TRUSTEE OF SUCH TRUST. Plaintiff, vs. wmwwwmwmmmwmwmmmwwmmmmmm TOLLESON PRIVATE BANK. ACTING INDIVIDUALLY AND AS A (IO-TRUSTEE OF SUCH 298T“ JUDICIAL DISTRICT TRUST. and STEPHEN T. WINN. ACTING INDIVIDUALLY AND AS TRUSTEE OF THE SEREN CAPITAL CHRISTOPHER S. WINN I998 DYNASTY TRUST. Defendants. vs. DAVID L. WINN AND CAROL WINN DUNAWAY. Nominal Defendants. DALLAS COUNTY, TEXAS RETURN OF SERVICE Came to my hand on Thursday, March 9, 2023 at 4:48 PM, Executed at: 4143 MAPLE AVENUE, SUITE 400, DALLAS, TX 75219 at [:25 PM, on Friday, March 10, 2023, by delivering to the within named: STEVEN T. WIN N, ACTING AS CO-TRUSTEE OF THE 1998 DYNASTY TRUST by delivering to General Counsel, MEGAN SMALE a true copy of this CITATION and PLAINTIFF ’8 ORIGINAL PETITION having first endorsed thereon the date of the delivery. BEFORE ME. the undersigned authority. on this day personally appeared Adil Tadli who other being duly sworn on oath states: "My name is Adil Tadli. am a person not less than eighteen (18} years of age and I am competent to make this oath. I am a resident of the State of Texas. I have I nor related or affiliated personal knowledge of the facts and statements contained herein and aver that each is true and correct. I am not a party to with any party to this suit. i have no interest in the outcome of the suit. I have never been convicted of a felony or of a misdemeanor involving moral as they apply to service of turpitude. I am familiar with the Texas Rules of Civil Procedure, and the Texas Civil Practice and Remedies Codes and Justice process. I am certified by the Judicial Branch Certification Commission to deliver citations and other notices from any District, County Courts in and for the State of Texas in compliance with rule 103 and 50l.2 ol'thc TRCP.” By'' 2%” \J' AdII Tndli - PSC1206 - Exp (ISIJIIM served@specialdelivery.eom Subscribed and Sworn to by Adil Tadll, Before Me, the undersigned authority, on this [£16 day of March, 2023 "H .plii BRITTNEY LEIGH woooALL' Notary Public ate of Texas STATE OF TEXAS Notary Public In ad for the IDMZQTQOZO-i' Comm. Ex Saw 32.1 i.» FORM NO. 353-3—CITATION THE STATE OF TEXAS ESERVE CITATION To: STEVEN T. WINN, ACTING AS CO-TRUSTEE OF THE 1998 DYNASTY TRUST 4143 MAPLE AVENUE, SUITE 400 DALLAS, TEXAS 75219 GREETINGS: You have been sued. You may employ an attorney. If you or your attorney do not file a written CHRISTOPHER S WINN answer with the clerk who issued this citation by 10 o'clock am. on the Monday next following the _\_r_s. expiration of twenty days after you were served this citation and ORIGINAL petition, a default TOLLESON PRIVATE BANE, et al judgment may be taken against you. In addition to filing a written answer with the clerk, you may be required to make initial disclosures to the other parties of this suit. These disclosures generally must be made no later than 30 days after you file your answer with the clerk. Find out more at ISSUED TexasLawHelp.org. Your answer should be addressed to the clerk of the 298th District Court at on this the 9th day of March, 2023 600 Commerce Street, Dallas, Texas 75202. ACTING INDIVIDUALLY AS THE Said Plaintiff being CHRISTOPHER S WINN, FELICIA PITRE PRIMARY BENEFICIARY OF THE SEREN CAPITAL CHRISTOPHER S. WINN 1998 Clerk District Courts, DYNASTY TRUST AND ACTING DERIVATIVELY ON BEHALF OF THE TRUSTEE OF Dallas County, Texas SUCH TRUST u By: GAY LANE Deputy Filed in said Court 24th day of February, 2023 against Attorney for Plaintiff TOLLESON PRIVATE BANK, ACTING INDIVIDUALLY AND AS A CO- TRUSTEE OF FRANK N IKARD SUCH TRUST ; STEPHEN T WINN, ACTING INDIVIDUALLY AND AS TRUSTEE OF 400WEST 15TH ST THE SEREN CAPITAL CHRISTOPHER S. WINN 1998 DYNASTY TRUST; DAVID L. SUITE 975 WINN; CAROL WIN N DUNAWAY, NOMINAL DEFENDANTS AUSTIN TX 7870] 512-472-2884 For Suit, said suit being numbered DC-23-02606, the nature of which demand is as follows: ikard®igilaw.com Suit on OTHER (CIVIL) etc. as shown on said petition, a copy of which accompanies DALLAS COUNTY this citation. If this citation is not served, it shall be returned unexecuted. SERVICE FEES NOT PAID WITNESS: FELICIA PITRE, Clerk of the District Courts of Dallas, County Texas. Given under my hand and the Seal of said Court at office on this the 9th day of March, 2023 ATTEST: FELICIA PITRE, Clerk of the District Courts of Dallas County, Texas gull, ‘8 I 9‘ ,& By 3 , Deputy 2,, GAY LANE as “W‘s”! OFFICER’S RETURN Cause No. DC-23-02606 Court No.: 298th District Court Style: CHRISTOPHER S WINN VS. TOLLESON PRIVATE BANK, ct al Came to hand on the day of , 20 , at o'clock .M. Executed at , within the County of at o'clock .M. on the day of , 20 , by delivering to the within named each, in person, a true copy of this Citation together with the accompanying copy of this pleading, having first endorsed on same date of delivery. The distance actually traveled by me in serving such process was miles and my fees are as follows: To certify which witness my hand. For serving Citation $ For mileage $ of County, For Notary $ By Deputy (Must be verified if served outside the State of Texas.) Signed and sworn to by the said before me this day of . 20 , to certify which witness my hand and seal of office. Notary Public County