On February 24, 2023 a
Answer
was filed
involving a dispute between
Winn, Christopher S,
and
Dunaway, Carol Winn,
Tolleson Private Bank,
Winn, David L.,
Winn, Stephen T,
for OTHER (CIVIL)
in the District Court of Dallas County.
Preview
FILED
4/3/2023 9:36 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Loaidi Grove DEPUTY
CAUSE NO. DC-23-02606
CHRISTOPHER S. WINN, ACTING IN THE DISTRICT COURT OF
INDIVIDUALLY AS THE PRIMARY
BENEFICIARY OF THE SEREN
CAPITAL CHRISTOPHER S. WINN
1998 DYNASTY TRUST AND ACTING
DERIVATIVELY ON BEHALF OF
THE TRUSTEE OF SUCH TRUST,
Plaintgfis
V.
TOLLESON PRIVATE BANK, ACTING
INDIVIDUALLY AND AS A CO- DALLAS COUNTY, TEXAS
TRUSTEE OF SUCH TRUST, and
STEPHEN T. WINN, ACTING
INDIVIDUALLY AND AS TRUSTEE
OF THE SEREN CAPITAL
CHRISTOPHER S. WINN 1998
DYNASTY TRUST,
Defendants,
v.
DAVID L. WINN AND CAROL WINN
DUNAWAY,
Nominal Defendants, 298T“ JUDICIAL DISTRICT
TOLLESON PRIVATE BAN K’S ORIGINAL ANSWER
Tolleson Private Bank (“Tolleson”), acting individually and as co-trustee of The Seren Capital
Christopher S. Winn 1998 Dynasty Trust (the “Trust”), files this, its Original Answer to the Plaintiffs’
Original Petition (the “Petition”) and states as follows:
General Denial
Tolleson generally denies each allegation in the Petition and demands strict proof thereof.
Afirmative Defenses
1. Plaintiffs claims in this action are barred, in whole or in part by limitations.
2. Plaintist claims in this action are barred in Whole or in part by release.
3. Plaintiffs claims in this action are barred in Whole or in part by collateral estoppel.
4. Plaintiffs claims in this action are barred in Whole or in part by waiver.
5. Plaintiffs claims in this action are barred in Whole or in part by ratification.
6. Plaintiffs claims in this action are barred in Whole or in part by his indemnity.
Prayer for Relief
WHEREFORE, Tolleson requests that the Court grant the following:
1. Deny all relief sought by Plaintiff;
2. Grant judgment in favor of Tolleson;
3. Award Tolleson its legal fees, csots and expenses; and
4. For such other relief as is just and necessary.
DATED: April 4, 2023 Respectfully submitted,
—
/4‘/WWW M. Til/om”
Jeffrey M. Tillotson
Texas Bar No. 20039200
jtillotson@tillotsonlaw.com
J. Austen Irrobali
Texas Bar No. 24092564
airrobali@tillotsonlaw.com
TILLOTSON JOHNSON & PAITON
1201 Main Street, Suite 1300
Dallas, Texas 75202
(214) 382-3041 Telephone
(214) 292—6564 Facsimile
COUNSEL FOR DEFENDANT
TOLLESON PRIVATE BANK
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing document was served
on all counsel of record herein by E—Service on April 4, 2023.
/.r/ M, Til/0m”
[Q‘fi‘ev
Jeffrey M. Tillotson
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.
Jeffrey Tillotson on behalf of Jeffrey M. Tillotson
Bar No. 20039200
swade@tillotsonlaw.com
Envelope ID: 74297445
Filing Code Description: Original Answer - General Denial
Filing Description:
Status as of 4/4/2023 12:12 PM CST
Associated Case Party: CHRISTOPHERSWINN
Name BarNumber Email TimestampSubmitted Status
Kiara Dial kdial@cstrial.com 4/4/2023 8:38:49 AM SENT
Alan Loewinsohn aloewinsohn@mckoolsmith.com 4/4/2023 8:38:49 AM SENT
Jennifer Barall jbarall@mckoolsmith.com 4/4/2023 8:38:49 AM SENT
Carson Young cyoung@mckoolsmith.com 4/4/2023 8:38:49 AM SENT
Frank N. lkard fni@ikardlaw.com 4/4/2023 8:38:49 AM SENT
Steve Skarnulis skarnulis@cstrial.com 4/4/2023 8:38:49 AM SENT
Benjamin D.Evans bevans@cstrial.com 4/4/2023 8:38:49 AM SENT
Associated Case Party: TOLLESON PRIVATE BANK
Name BarNumber Email TimestampSubmitted Status
Jeffrey M. Tillotson 20039200 jtillotson@tillotsonlaw.com 4/4/2023 8:38:49 AM SENT
Associated Case Party: STEPHENTWINN
Name BarNumber Email TimestampSubmitted Status
Will Hartnett will@hartnettlawfirm.com 4/4/2023 8:38:49 AM SENT
Jay Hartnett jay@hartnettlawfirm.com 4/4/2023 8:38:49 AM SENT
Jim Hartnett, Jr. jim@hartnettlawfirm.com 4/4/2023 8:38:49 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Lauren Lopez llopez@tillotsonlaw.com 4/4/2023 8:38:49 AM 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.
Jeffrey Tillotson on behalf of Jeffrey M. Tillotson
Bar No. 20039200
swade@tillotsonlaw.com
Envelope ID: 74297445
Filing Code Description: Original Answer - General Denial
Filing Description:
Status as of 4/4/2023 12:12 PM CST
Case Contacts
Jeffrey MTillotson jtillotson@tillotsonlaw.com 4/4/2023 8:38:49 AM SENT
Joseph Alrrobali airrobali@tillotsonlaw.com 4/4/2023 8:38:49 AM SENT
Kira Lytle klytle@ti|lotsonlaw.com 4/4/2023 8:38:49 AM SENT
TJP Service tillotsonjohnsonpatton@gmail.com 4/4/2023 8:38:49 AM SENT
Document Filed Date
April 03, 2023
Case Filing Date
February 24, 2023
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED 4/3/2023 9:36 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Loaidi Grove DEPUTY CAUSE NO. DC-23-02606 CHRISTOPHER S. WINN, ACTING IN THE DISTRICT COURT OF INDIVIDUALLY AS THE PRIMARY BENEFICIARY OF THE SEREN CAPITAL CHRISTOPHER S. WINN 1998 DYNASTY TRUST AND ACTING DERIVATIVELY ON BEHALF OF THE TRUSTEE OF SUCH TRUST, Plaintgfis V. TOLLESON PRIVATE BANK, ACTING INDIVIDUALLY AND AS A CO- DALLAS COUNTY, TEXAS TRUSTEE OF SUCH TRUST, and STEPHEN T. WINN, ACTING INDIVIDUALLY AND AS TRUSTEE OF THE SEREN CAPITAL CHRISTOPHER S. WINN 1998 DYNASTY TRUST, Defendants, v. DAVID L. WINN AND CAROL WINN DUNAWAY, Nominal Defendants, 298T“ JUDICIAL DISTRICT TOLLESON PRIVATE BAN K’S ORIGINAL ANSWER Tolleson Private Bank (“Tolleson”), acting individually and as co-trustee of The Seren Capital Christopher S. Winn 1998 Dynasty Trust (the “Trust”), files this, its Original Answer to the Plaintiffs’ Original Petition (the “Petition”) and states as follows: General Denial Tolleson generally denies each allegation in the Petition and demands strict proof thereof. Afirmative Defenses 1. Plaintiffs claims in this action are barred, in whole or in part by limitations. 2. Plaintist claims in this action are barred in Whole or in part by release. 3. Plaintiffs claims in this action are barred in Whole or in part by collateral estoppel. 4. Plaintiffs claims in this action are barred in Whole or in part by waiver. 5. Plaintiffs claims in this action are barred in Whole or in part by ratification. 6. Plaintiffs claims in this action are barred in Whole or in part by his indemnity. Prayer for Relief WHEREFORE, Tolleson requests that the Court grant the following: 1. Deny all relief sought by Plaintiff; 2. Grant judgment in favor of Tolleson; 3. Award Tolleson its legal fees, csots and expenses; and 4. For such other relief as is just and necessary. DATED: April 4, 2023 Respectfully submitted, — /4‘/WWW M. Til/om” Jeffrey M. Tillotson Texas Bar No. 20039200 jtillotson@tillotsonlaw.com J. Austen Irrobali Texas Bar No. 24092564 airrobali@tillotsonlaw.com TILLOTSON JOHNSON & PAITON 1201 Main Street, Suite 1300 Dallas, Texas 75202 (214) 382-3041 Telephone (214) 292—6564 Facsimile COUNSEL FOR DEFENDANT TOLLESON PRIVATE BANK CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing document was served on all counsel of record herein by E—Service on April 4, 2023. /.r/ M, Til/0m” [Q‘fi‘ev Jeffrey M. Tillotson 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. Jeffrey Tillotson on behalf of Jeffrey M. Tillotson Bar No. 20039200 swade@tillotsonlaw.com Envelope ID: 74297445 Filing Code Description: Original Answer - General Denial Filing Description: Status as of 4/4/2023 12:12 PM CST Associated Case Party: CHRISTOPHERSWINN Name BarNumber Email TimestampSubmitted Status Kiara Dial kdial@cstrial.com 4/4/2023 8:38:49 AM SENT Alan Loewinsohn aloewinsohn@mckoolsmith.com 4/4/2023 8:38:49 AM SENT Jennifer Barall jbarall@mckoolsmith.com 4/4/2023 8:38:49 AM SENT Carson Young cyoung@mckoolsmith.com 4/4/2023 8:38:49 AM SENT Frank N. lkard fni@ikardlaw.com 4/4/2023 8:38:49 AM SENT Steve Skarnulis skarnulis@cstrial.com 4/4/2023 8:38:49 AM SENT Benjamin D.Evans bevans@cstrial.com 4/4/2023 8:38:49 AM SENT Associated Case Party: TOLLESON PRIVATE BANK Name BarNumber Email TimestampSubmitted Status Jeffrey M. Tillotson 20039200 jtillotson@tillotsonlaw.com 4/4/2023 8:38:49 AM SENT Associated Case Party: STEPHENTWINN Name BarNumber Email TimestampSubmitted Status Will Hartnett will@hartnettlawfirm.com 4/4/2023 8:38:49 AM SENT Jay Hartnett jay@hartnettlawfirm.com 4/4/2023 8:38:49 AM SENT Jim Hartnett, Jr. jim@hartnettlawfirm.com 4/4/2023 8:38:49 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Lauren Lopez llopez@tillotsonlaw.com 4/4/2023 8:38:49 AM 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. Jeffrey Tillotson on behalf of Jeffrey M. Tillotson Bar No. 20039200 swade@tillotsonlaw.com Envelope ID: 74297445 Filing Code Description: Original Answer - General Denial Filing Description: Status as of 4/4/2023 12:12 PM CST Case Contacts Jeffrey MTillotson jtillotson@tillotsonlaw.com 4/4/2023 8:38:49 AM SENT Joseph Alrrobali airrobali@tillotsonlaw.com 4/4/2023 8:38:49 AM SENT Kira Lytle klytle@ti|lotsonlaw.com 4/4/2023 8:38:49 AM SENT TJP Service tillotsonjohnsonpatton@gmail.com 4/4/2023 8:38:49 AM SENT