On February 24, 2023 a
Stipulation,Agreement
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
4/18/2023 4:19 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Lafonda Sims 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. VVINN 1998 DYNASTY
TRUST AND ACTING DERIVATIVELY ON
BEHALF OF THE TRUSTEE OF SUCH TRUST,
Plaintiff,
VS. DALLAS COUNTY, TEXAS
TOLLESON PRIVATE BANK, ACTING
INDIVIDUALLY AND AS A CO—TRUSTEE OF
SUCH TRUST, and STEPHEN T. WINN,
ACTING INDIVIDUALLY AND AS TRUSTEE
OF THE SEREN CAPITAL CHRISTOPHER S.
WINN 1998 DYNASTY TRUST,
Defendants,
VS.
DAVID L. WINN AND CAROL WINN
DUNAWAY 298th JUDICIAL DISTRICT
Nominal Defendants.
AGREED MOTION FOR ENTRY OF
CONFIDENTIALITY AND PROTECTIVE ORDER
Plaintiff files this Motion for Entry of Confidentiality and Protective Order in
advance of discovery that will include confidential information and materials.
I.
1. This case is not currently set for trial. Discovery is beginning.
2. The parties anticipate the exchange of sensitive personal, financial and
business information and documents during discovery. Therefore, a protective order is
needed. A standard, broad form of Confidentiality and Protective Order is attached as
AGREED MOTION FOR ENTRY OF AGREED DOCKET CONTROL ORDER—PAGE 1
Exhibit A and was circulated with the parties prior to filing this motion. Plaintiff asks for
the entry of the order.
PRAYER
For these reasons, Plaintiff prays that this Court grant this motion and enter the
Confidentiality and Protective Order attached to this motion as Exhibit A.
Respectfully submitted,
/s/ Steve Skarnulis
Steve Skarnulis
State Bar No. 24041924
skarnulis@cstrial.com
Benjamin D. Evans
bevans@cstrial.com
State Bar No. 24081285
CAIN & SKARNULIS PLLC
303 Colorado Street, Suite 2850
Austin, Texas 78701
512-477-5000
512—477-5011—Facsimi1e
Frank N. Ikard, Jr.
State Bar N0. 10386000
fni@ikardlaw.com
IKARD LAW P.C.
2630 Exposition, Suite 118
Austin, Texas 78703
512-472-6696
512-472-3669—Facsimile
Alan Loewinsohn
State Bar N0. 12481600
aloewinsohn@mckoolsmith.com
Carson Young
State Bar N0. 24106613
cyoung@mckoolsmith.c0m
MCKOOL SMITH, P.C.
300 Crescent Court, Suite 1500
Dallas, Texas 75201
214-978-4018
ATTORNEYS FOR PLAINTIFF
AGREED MOTION FOR ENTRY OF AGREED DOCKET CONTROL ORDER—PAGE 2
CERTIFICATE OF CONFERENCE
I hereby certify that the parties have conferred on the form and substance of the
Confidentiality and Protective Order and that the parties were able to reach agreement on
the same.
/s/ Steve Skarnulis
Steve Skarnulis
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the Motion for Entry of Confidentiality and
Protective Order has been forwarded to all counsel of record in accordance with the Texas
Rules of Civil Procedure on this 18th day of April 2023, as follows:
Method of Service Party(ies) Counsel
Electronic Service Defendant Stephen T. Jim Hartnett
Winn State Bar No. 09169000
jim@hartnettlawfirm.com
Jay David Hartnett
State Bar No. 09169300
THE HARTNETT LAW FIRM
2920 N. Pearl Street
Dallas, Texas 75201
214-742-4655
Electronic Service Defendant Tolleson Jeffrey M. Tillotson
Private Bank State Bar No. 20039200
jtillotson@tillotsonlaw.c0m
J. Austen Irrobali
State Bar No. 24092564
airrobali@tillotsonlaw.com
TILLOTSON JOHNSON & PATTON
1201 Main Street, Suite 1300
Dallas, Texas 75202
214—382—3041
21$292—656i—Facsimile
/s/ Steve Skarnulis
Steve Skarnulis
AGREED MOTION FOR ENTRY OF AGREED DOCKET CONTROL ORDER—PAGE 3
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.
Kiara Dial on behalf of Steve Skarnulis
Bar No. 24041924
kdial@cstrial.com
Envelope ID: 74823314
Filing Code Description: Motion - Protect
Filing Description: AGREED MOTIONFOR ENTRY OF
CONFIDENTIALITY & PROTECTIVE ORDER
Status as of 4/20/2023 8:10 AM CST
Associated Case Party: CHRISTOPHERSWINN
Name BarNumber Email TimestampSubmitted Status
Kiara Dial kdial@cstrial.com 4/19/2023 4:08:56 PM SENT
Alan Loewinsohn aloewinsohn@mckoolsmith.com 4/19/2023 4:08:56 PM SENT
Jennifer Barall jbarall@mckoolsmith.com 4/19/2023 4:08:56 PM SENT
Carson Young cyoung@mckoolsmith.com 4/19/2023 4:08:56 PM SENT
Frank N. lkard fni@ikardlaw.com 4/19/2023 4:08:56 PM SENT
Steve Skarnulis skarnulis@cstrial.com 4/19/2023 4:08:56 PM SENT
Benjamin D.Evans bevans@cstrial.com 4/19/2023 4:08:56 PM SENT
Associated Case Party: TOLLESON PRIVATE BANK
Name BarNumber Email TimestampSubmitted Status
Jeffrey M. Tillotson 20039200 jtillotson@tillotsonlaw.com 4/19/2023 4:08:56 PM SENT
Associated Case Party: STEPHENTWINN
Name BarNumber Email TimestampSubmitted Status
Will Hartnett will@hartnettlawfirm.com 4/19/2023 4:08:56 PM SENT
Jay Hartnett jay@hartnettlawfirm.com 4/19/2023 4:08:56 PM SENT
Jim Hartnett, Jr. jim@hartnettlawfirm.com 4/19/2023 4:08:56 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
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.
Kiara Dial on behalf of Steve Skarnulis
Bar No. 24041924
kdial@cstrial.com
Envelope ID: 74823314
Filing Code Description: Motion - Protect
Filing Description: AGREED MOTIONFOR ENTRY OF
CONFIDENTIALITY & PROTECTIVE ORDER
Status as of 4/20/2023 8:10 AM CST
Case Contacts
Lauren Lopez llopez@tillotsonlaw.com 4/19/2023 4:08:56 PM SENT
Jeffrey MTillotson jtillotson@tillotsonlaw.com 4/19/2023 4:08:56 PM SENT
Joseph Alrrobali airrobali@tillotsonlaw.com 4/19/2023 4:08:56 PM SENT
Kira Lytle klytle@tillotsonlaw.com 4/19/2023 4:08:56 PM SENT
TJP Service tillotsonjohnsonpatton@gmail.com 4/19/2023 4:08:56 PM SENT
Document Filed Date
April 18, 2023
Case Filing Date
February 24, 2023
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED 4/18/2023 4:19 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Lafonda Sims 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. VVINN 1998 DYNASTY TRUST AND ACTING DERIVATIVELY ON BEHALF OF THE TRUSTEE OF SUCH TRUST, Plaintiff, VS. DALLAS COUNTY, TEXAS TOLLESON PRIVATE BANK, ACTING INDIVIDUALLY AND AS A CO—TRUSTEE OF SUCH TRUST, and STEPHEN T. WINN, ACTING INDIVIDUALLY AND AS TRUSTEE OF THE SEREN CAPITAL CHRISTOPHER S. WINN 1998 DYNASTY TRUST, Defendants, VS. DAVID L. WINN AND CAROL WINN DUNAWAY 298th JUDICIAL DISTRICT Nominal Defendants. AGREED MOTION FOR ENTRY OF CONFIDENTIALITY AND PROTECTIVE ORDER Plaintiff files this Motion for Entry of Confidentiality and Protective Order in advance of discovery that will include confidential information and materials. I. 1. This case is not currently set for trial. Discovery is beginning. 2. The parties anticipate the exchange of sensitive personal, financial and business information and documents during discovery. Therefore, a protective order is needed. A standard, broad form of Confidentiality and Protective Order is attached as AGREED MOTION FOR ENTRY OF AGREED DOCKET CONTROL ORDER—PAGE 1 Exhibit A and was circulated with the parties prior to filing this motion. Plaintiff asks for the entry of the order. PRAYER For these reasons, Plaintiff prays that this Court grant this motion and enter the Confidentiality and Protective Order attached to this motion as Exhibit A. Respectfully submitted, /s/ Steve Skarnulis Steve Skarnulis State Bar No. 24041924 skarnulis@cstrial.com Benjamin D. Evans bevans@cstrial.com State Bar No. 24081285 CAIN & SKARNULIS PLLC 303 Colorado Street, Suite 2850 Austin, Texas 78701 512-477-5000 512—477-5011—Facsimi1e Frank N. Ikard, Jr. State Bar N0. 10386000 fni@ikardlaw.com IKARD LAW P.C. 2630 Exposition, Suite 118 Austin, Texas 78703 512-472-6696 512-472-3669—Facsimile Alan Loewinsohn State Bar N0. 12481600 aloewinsohn@mckoolsmith.com Carson Young State Bar N0. 24106613 cyoung@mckoolsmith.c0m MCKOOL SMITH, P.C. 300 Crescent Court, Suite 1500 Dallas, Texas 75201 214-978-4018 ATTORNEYS FOR PLAINTIFF AGREED MOTION FOR ENTRY OF AGREED DOCKET CONTROL ORDER—PAGE 2 CERTIFICATE OF CONFERENCE I hereby certify that the parties have conferred on the form and substance of the Confidentiality and Protective Order and that the parties were able to reach agreement on the same. /s/ Steve Skarnulis Steve Skarnulis CERTIFICATE OF SERVICE I certify that a true and correct copy of the Motion for Entry of Confidentiality and Protective Order has been forwarded to all counsel of record in accordance with the Texas Rules of Civil Procedure on this 18th day of April 2023, as follows: Method of Service Party(ies) Counsel Electronic Service Defendant Stephen T. Jim Hartnett Winn State Bar No. 09169000 jim@hartnettlawfirm.com Jay David Hartnett State Bar No. 09169300 THE HARTNETT LAW FIRM 2920 N. Pearl Street Dallas, Texas 75201 214-742-4655 Electronic Service Defendant Tolleson Jeffrey M. Tillotson Private Bank State Bar No. 20039200 jtillotson@tillotsonlaw.c0m J. Austen Irrobali State Bar No. 24092564 airrobali@tillotsonlaw.com TILLOTSON JOHNSON & PATTON 1201 Main Street, Suite 1300 Dallas, Texas 75202 214—382—3041 21$292—656i—Facsimile /s/ Steve Skarnulis Steve Skarnulis AGREED MOTION FOR ENTRY OF AGREED DOCKET CONTROL ORDER—PAGE 3 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. Kiara Dial on behalf of Steve Skarnulis Bar No. 24041924 kdial@cstrial.com Envelope ID: 74823314 Filing Code Description: Motion - Protect Filing Description: AGREED MOTIONFOR ENTRY OF CONFIDENTIALITY & PROTECTIVE ORDER Status as of 4/20/2023 8:10 AM CST Associated Case Party: CHRISTOPHERSWINN Name BarNumber Email TimestampSubmitted Status Kiara Dial kdial@cstrial.com 4/19/2023 4:08:56 PM SENT Alan Loewinsohn aloewinsohn@mckoolsmith.com 4/19/2023 4:08:56 PM SENT Jennifer Barall jbarall@mckoolsmith.com 4/19/2023 4:08:56 PM SENT Carson Young cyoung@mckoolsmith.com 4/19/2023 4:08:56 PM SENT Frank N. lkard fni@ikardlaw.com 4/19/2023 4:08:56 PM SENT Steve Skarnulis skarnulis@cstrial.com 4/19/2023 4:08:56 PM SENT Benjamin D.Evans bevans@cstrial.com 4/19/2023 4:08:56 PM SENT Associated Case Party: TOLLESON PRIVATE BANK Name BarNumber Email TimestampSubmitted Status Jeffrey M. Tillotson 20039200 jtillotson@tillotsonlaw.com 4/19/2023 4:08:56 PM SENT Associated Case Party: STEPHENTWINN Name BarNumber Email TimestampSubmitted Status Will Hartnett will@hartnettlawfirm.com 4/19/2023 4:08:56 PM SENT Jay Hartnett jay@hartnettlawfirm.com 4/19/2023 4:08:56 PM SENT Jim Hartnett, Jr. jim@hartnettlawfirm.com 4/19/2023 4:08:56 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status 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. Kiara Dial on behalf of Steve Skarnulis Bar No. 24041924 kdial@cstrial.com Envelope ID: 74823314 Filing Code Description: Motion - Protect Filing Description: AGREED MOTIONFOR ENTRY OF CONFIDENTIALITY & PROTECTIVE ORDER Status as of 4/20/2023 8:10 AM CST Case Contacts Lauren Lopez llopez@tillotsonlaw.com 4/19/2023 4:08:56 PM SENT Jeffrey MTillotson jtillotson@tillotsonlaw.com 4/19/2023 4:08:56 PM SENT Joseph Alrrobali airrobali@tillotsonlaw.com 4/19/2023 4:08:56 PM SENT Kira Lytle klytle@tillotsonlaw.com 4/19/2023 4:08:56 PM SENT TJP Service tillotsonjohnsonpatton@gmail.com 4/19/2023 4:08:56 PM SENT