Letter,Correspondence: ANN H. PLETTA, et al vs. CECILIA SOO, et al

On May 14, 2020 a Letter,Correspondence was filed involving a dispute between Pletta, Ann H., Pletta, Timothy G, Timothy G. Pletta Revocable Trust, and Creekview Owners Association, Soo, Cecilia, Soo, Ken, for PROPERTY in the District Court of Dallas County.

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FILED
6/1/2022 2:09 PM
FELICIA PITRE
DISTRICT CLERK
THE LAW OFFICES 01" DALLAS 00., TEXAS
LoaidiGroveDEPUTY

TIMOTHY GERARD PLETTA
Attorney and Counselor DA YL 1995 e 1996
Dallas Bar Association Member Ctr-Chair Professionalism
150 Bethe! Road
Coppell, Texas 75019 Facsimile.- (972) 462-0465
Telephone: (972) 462-0321

June 1, 2022

VIA E-MAIL: criley®dykema.com

Dykema Gossett, LLC.
Mr. Cliff Riley
1717 Main Street, Suite 4200
Dallas, Texas 75201

Re: Cause No: DCZO-OﬁSlﬁ—M
nn H. letta v. T'moth . Pletta stee f0 and on behalf of the Ann H.
Pletta and Timothy G. Pletta Revocable Trust v. @ilia $99 and Kenneth §oo,
et al.

Dear Mr. Riley:

This is to conﬁrm our telephone conversation this morning confirming you oppose
Plaintiff's Motion to Strike and Sanctions relating to your late filed (101 days) TCPA Motion to
Dismiss despite having no legal authority to do so.

At ﬁrst you attempted to argue, the slander per se motion "was part of" the previous
TCPA Motion to Dismiss, only for me to remind you that you admitted Gudicial admission) to
the Court on the record the slander per se claim was "not part of the previous TCPA. Motion to
Dismiss."

Second, lpointed out that if you contend the slander per so "was part of" the previous
TCPA Motion to Dismiss, and you were not granted the relief you sought, then your remedy was
to appeal the ruling from Court of Appeals, which you did not.

Third, as the slander per se claim was served August 12, 2020, 51 days elapsed until
your Notice of Appeal and 50 days elapsed since the Court of Appeals Mandate, making your
May 27, 2022 TCPA Motion to Dismiss 41 days late as CPRC 27.00360 requires the Motion
to Dismiss be filed within 60 days of service. See Balger V. Monsanto (10., 111 S.W.3d 158,
160 (Tex 2003); Jordan v. Hall, 510 S.W.3d 194, 198-199 (Tex. App. Houston [lst Dist.]
--

2016).

To these direct arguments during our conference, you had no response stating, "well...
were gonna appeal this too if we lose."
Dykema Gossett, LLC.
Mr. Cliff Riley
June I, 2022
Page - 2
-

Such "fast and loose" practice of law using a late (101 days) TCPA Motion to Dismiss
as a weapon to force Plaintiff to "marshall its evidence" to respond is nothing less than an
improper use of the TCPA and subjects Dykema Gossett and the 800‘s to liability, jointly
and
severally, for sunoticms related to your pleading having absolutely no basis in law or in fact.

Finally, I made you aware the underlying criminal complaint as alleged by your clients
was dismissed on May 19, 2022, also having no basis in law or in fact, a copy of which is
attached hereto and incorporated herein by reference.

Kindly review the law and facts at issue and if your May 27, 2022 TCPA Motion to
Dismiss is not dismissed by 2:00 pm. today, we will have no choice but to proceed.

W” “to.
Timothy G. Esq.

cc: trial court
opposing counsels
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Baker 1.". Mons-unto (Tm, m. 5.112;“! 138 (Tex. 2:103]

111 S-W.3d 158 represented Monsanto in other err-going litigation
Kelly K. BAKER, et al., Petitioners, over the Brio site. The law firm, however, did not
V. respond to intervenors' claims except to say by
MONSANTO COMPANY, Respondent. letter that they would not accept service on
N 0. 02-0603. Monsanto's behalf.
Supreme Court of Texas.
July 3, 2003. Plaintiffs subsequently served citation on
Rehearing Denied August 21, 2003. Monsanto on June 25, 1995, and the same law
firm ﬁled an answer for the defendant on July 7,
[111 S.W.3d 159] 1995. In an apparent attempt to avoid appearing
generally for purposes of the intervention, the
James B. Manley, James B. Manley, P.C., answer stated that it was "in answer to the
Pasadena, for Petitioner. petitions of those plaintiffs who have served
Monsanto." The answer was not served on
Phyllis J. Cohen, Jonathan B. Shoebotham, intervenors, and intervenors made no subsequent
Porter 8.: Hedges, LLP, Houston, for Respondent. attempt to serve Monsanto before limitations ran.

PER CURIAM. On June 5, 1997, more than two years after
the intervention, Monsanto moved for summary
The issue before us is whether intervenors
judgment, asserting that the intervenors' claims
must serve citation on a defendant to stop the were barred by limitations because Monsanto had
statute of limitaticms from running on their not been formally served with citation. The trial
claims when the intervention is filed before the court granted the motion and subsequently
defendant has appeared to answer the plaintiffs‘ severed the interventors' claims, making the
original petition. After the plaintiffs ﬁled their summary judgment ﬁnal. The court of appeals
original petition, but before the defendant was afﬁrmed the summary judgment, concluding that
served, intervenors petitioned the court to Baker's attempted service by certified mail on
intervene. Although intervenors promptly notiﬁed Monsanto's counsel was invalid and thus had
defendant's counsel of their intentions, they did failed to tell limitations. 77 S.W.3d at 481452.
not save citation on the defendant. Two years
Relying on McWillioms v. Snap-Poe Corp, 476
later, defendant moved for summary judgment S.W.2d 941 (Tex.Civ.App.-Houston [1st Dist]
against the intervenors, asserting limitations. The 1971, writ rei‘d n.r.e.), the court concluded that
trial court granted the motion, and the court of intervenors had to serve Monsanto with citation
appeals afﬁrmed. that judgment. 77 S.W.3d 477. because when intervenors "ﬁled their petition in
Because the summary judgment record does not intervention Monsanto had yet to be served by
establish that intervenors' claims are barred by
plaintiffs and appear as a party to the underlying
limitations, we reverse the court of appeals' lawsuit." Id. at 480-81.
judgment and remand the case to the trial court.
When McWilliums was decided, Texas Rule
On February 24, 1995, plaintiffs ﬁled suit of Civil Procedure 60, the intervention rule,
against Monsanto Co. and others alleging injuries speciﬁcally referenced another rule regarding the
arising from two toxic waste sites known as the ﬁling and service of pleadings. Rule 60 then
Brio/BOP Superfund sites. On May 18, 1995, provided:
Kelly K. Baker and others ﬁled their petition in
intervention, delivering a copy by certiﬁed mail to Any party may intervene, subject to being
the law ﬁrm of Woodard, Hall 8: Primm. Although stricken out by the court for sufﬁcient cause on
Monsanto had not yet answered the plaintiffs' the motion of the Opposite party; and such
suit, this law ﬁrm was apparently identiﬁed as intervenor shall, in accordance
likely defense counsel because it already
'Ilakur 1:. Monsanto C0” Ill S-VV.3d 158 (fax. 2:}(J3)

[111 S.W.3d 160] must serve citation on the plaintiff, if the plaintiff
does not make any further appearance in the came
with Rule 72, notify the opposite party or his after the intervention. Id. McWiiiioms quoted
attorney of the ﬁling of such pleadings within ﬁve these principles from McDonald's Texas Civil
days from the ﬁling of same. Practice whose text remains substantially
unchanged today. It provides:
In 1990, Rule 60 was amended to provide the
following: Citation is necessary when the intervenor
asks afﬁrmative relief against a defendant who
Any party may intervene by ﬁling a pleading, has not appeared or a plaintiff who does not, by
subject to being stricken out by the court for any action subsequent to the intervention, appear
sufﬁcient cause on the motion of any party. thereon. It also is necessary as against any third
party sought to be brought in by intervention. But
TexR. Civ. P. 60. That same year the Court
parties before the court must take notice of the
repealed 1Rule 72, and its surviving provisions intervention when they are notiﬁed under Rule 21
moved to Rule 21. See TexR. Civ. P. 72 (repealed and 21a. In accordance with the rule generally as
1990), cmt. to 1990 change. Although the Court to the necessity of serving process on the ﬁling of
eliminated any reference to ﬁling and service a cross-claim where the defendant has appeared
from Rule 60's text, our comment to the 1990 in the action, a defendant who has answered must
amendment conﬁrms that we intended no answer an intervention seeking afﬁrmative relief
substantive change. This comment provides that
against him or her without awaiting further
"Rules 21 and 21a control notice and service of citation.
pleadings of intervenors." "remit. Civ. P. 60, cmt.
to 1990 change. 1McDonald and Carlson, Texas Civil Practice
§ 5:81 at 609 (1992 ed.) (citations omitted).
Typically, an intervention involves a claim
against persons who have already appeared. If Monsanto had not later appeared, then
Under these circumstances, the plea in delivering the petition in intervention by certiﬁed
intervention is properly served by any of the mail would have been ineffective to bring
methods provided in Rule 21a. See 5 William V. Monsanto within the jurisdiction of the court.
Dorsaneo III, Texas Litigation Guide § 82.09 at However, Monsanto made a general appearance
82—17 [2002). However, absent a subsequent when it answered the plaintiffs‘ complaint on July
appearance, service of citation is necessary 7, 1995. That appearance relieved the intervenors
against an original defendant when the intervenor of the responsibility to serve Monsanto with
seeks afﬁnnative relief against a defendant who citation, and the date on which limitations ceased
has not appeared at the time the intervention was to run was May 18, 1995, when the intervention
ﬁled. Id. The court of appeals concluded here that was ﬁled. Cf. Gont v. DeLeon, 786 S.W.2d 259,
because Monsanto had yet to appear when the 260 (Tex.1990) (filing of suit stops limitations if
intervenors ﬂied their pleadings, service of diligence is exercised in service). Monsanto's
citation was required under McWiHioms. answer further did not question

McWiliiams merely stated that intervenors [111 S.W.3d 161]
are required to serve citation on a defendant
when that defendant fails to appear and answer the court's jurisdiction, and thus its appearance
the plaintiff‘s petition. McWilliams, 476 S.W.2d at was not a limited one despite its attempt to
950. McWiiiioms also concluded that an restrict its answer only to "those plaintiffs who
intervenor must serve citation on any third-party have served Monsanto." See Tex.R. Civ. P. 1203
defendant it seeks to bring into the suit. Id. And if [special appearance}. Any defect in the
the intervenor‘s claim is against the plaintiff, it intervenors' service under Rule 2121 was cured by
'lhlkcl‘ 1 . Mimi-innit) ('11.. 111 SJ'VJJEI 158 {'l‘cx. 2.003}

that appearance. Sullivan 1:. Doyle, 108 Tex. 368,
194 S.W. 136, 137 {1917) (general appearance puts
defendant "before the court for all purposes"); see
also Tex.R. Civ. P. 121 (answer is appearance);
Perfect Union Lodge No. 10 of San Antonio u.
Intei'first Bank of San Antonio, 713 S.W.2d 391,
393 ('Tex.App.—San Antonio 1986), aﬂ‘d on other
grounds, 748 S.W.2d 218 (Tex.1988) (general
appearance in action waives any defect in the
manner of service). If Monsanto had any
complaint about the intewenors' premature
service under Rule 21a, its recourse was a motion
to quash. See Kawasaki Steel Corp. v. Middletou,
699 S.W.2d 199, 203 (Tex.1985) (motion to quash
is appropriate device to object to procedural error
in service).

Because Monsanto generally appeared in the
case before limitations had run on intervenors'
claims, intervcnors' action was not barred, and
the summaly judgment rendered in this case was
therefore erroneous. Accordingly, without hearing
oral argument, we grant Baker's petition for
review, reverse the court of appeals‘ judgment,
and remand the case to the trial court for further
proceedings consistent with this opinion.
Tex.R.App. P. 59.1.

Justice SCHNEIDER did not participate in
the decision.
Jordan v. Hall, 510 S.\\’.3tl 19.; ('l‘cx. App. 20m}

51o S.W.3d 194 In October 2015, Hall was running for mayor of
Houston. On October 25, 2015, Houston radio
Justin JORDAN, Appellant station Majic 102.1 FM aired a political radio ad
v. stating:
Benjamin HALL III, Appeliee
Ben Hall, this message is for you.
NO. 01w16woo43o—CV You can no longer lie to the voters of
Houston. You can no longer make
Court of Appeals of Texas, Houston (lst up stories about owning a radio
Dish). station that just aren't true. We will
not allow you to use Wayne
Opinion issued December 6, 2016 Dolceﬁno to do your dirty work and
you can‘t hide your association with
Oliver J. Brown, Houston, TX, for appellant. Confederate sympathizer Steve
Hotze. We know you took his
Benjamin L. Hall III, William L. Van Fleet II,
money. And you know Wayne
Houston, TX, for appellee. Dolceﬁno has a history of attacking
our black leaders. Ben Hall, exactly
[51o S.W.3d 196]
what does that say about you?
Panel consists of Justices Masscngale, Brown, and
Hall believed that Jordan, a former campaign
Huddle.
manager, placed the ad. Two days after the ad
OPINION aired, Hall sued Jordan in Harris County district
court for "telecommunications and wire fraud,
Rebeca Huddle, Justice money laundering, election code violations and
fraud, defamation and declaratory judgment
In this interlocutory appeal, Justin Jordan relief." Hall alleged that Jordan and several
challenges the trial court's denial, as untimely, of political entities that he controlled had conspired
Jordan's motion to dismiss under the Texas to unlawfully inﬂuence the election.
Citizens‘ Participation Act (TCPA). Benjamin Hall
III sued Jordan alleging that Jordan placed a Jordan did not await service of the lawsuit.
defamatory and illegal political radio Instead, on October 30, 2015, three days after the
advertisement about Hall Hall's suit was ﬁled, Jordan ﬁled a general denial and
during mayoral
campaign. Three days later, and without service of special exceptions. Jordan specially excepted to
the petition, Jordan ﬁled an answer with special Hall's defamation cause of action for failure to
exceptions. Jordan moved to dismiss the suit plead all the elements, and specially excepted to
under the TCPA five months later, and the trial the telecommunications, wire and mail fraud,
court denied the motion as untimely. On appeal, money laundering, and election law violations
Jordan contends the trial court erred by denying causes of action on the grounds that they were not
his motion as untimely because [1) the 60—day recognized causes of action under Texas law.
deadline to file a TCPA motion does not expire if a
On December 11, 2015, the trial court granted
defendant is not served with process, and (2) the
Jordan's special exceptions and ordered Hall to
60—day deadline is tolled by the trial court's order
replead his causes of action. On December 21,
requiring Hail to rcplead in response to Jordan's
2015, Hall ﬁled his ”First Supplement to
special exceptions. We affirm.
Plaintiff's Original Petition." The supplement
more speciﬁcally set forth elements of claims for
Background
mail fraud, telecommunications fraud, and money
laundering.
Jordan 1 . Hall. 51:) 53123:] 194 {'l‘ox. App. 2011'};

Three months later, on March 21, 2016, Jordan We review de novo a trial court's ruling on a
ﬁled a motion to dismiss under the TCPA, arguing motion to dismiss under the TCPA. Better Bus.
that the suit should be dismissed because it Bureau of Metro. Hous., Inc. v. John Moore
related to his placement of a political radio ad, Serve, Inc. , 441 S.W.3d 345, 353 (Tex. App.—
which was an exercise of his free speech rights. Houston [ast Dist} 2013, pet. denied). In
Hall objected to the motion on the grounds that it conducting this review, we review the pleadings
was untimely because section 27.00303) 0f the and evidence in a light favorable to the
TCPA requires a motion to be ﬁled by the 60th nonmovant. Newspaper Holdings, Inc. 11. Crazy
day after the date of service of the legal action. Hotel Assisted Living, Ltd. , 416 S.W.3d 71, 80—81
Jordan responded and argued that the deadline in (Tex. App—Houston [1st Dist] 2013, pet. denied}.
section 27.00301) had yet to expire because he
voluntarily appeared. In other words, Jordan Our primary concern when interpreting a statute
is the impress statutory language. See Galbraith
[510 S.W.3d 197] Eng'g Consultants, Inc. U. Pochucha , 290 S.W.3d
863, 867 (Tex. 2009). We apply the plain
argued that there had been no "service of the legal meaning of the text unless a different meaning is
action“ due to his voluntary appearance and, supplied by legislative deﬁnition or is apparent
therefore, the clock on the 60—day deadline in from the context or the plain meaning leads to
section 27.oo3(h) never began to run. absurd results. Marks 0. St. Luke‘s Episcopal
Hosp. , 319 S.W.3d 658, 663 (Tex. 2010). "We
The trial court entered an order denying Jordan's generally avoid construing individual provisions
motion as untimely. Jordan appealed. of a statute in isolation from the statute as a
whole[,]" R.R. Comm 'n of Tex. v. Tex. Citizens for
Discussion a Safe Future and Clean Water, 336 S.W.3d 619,
628 (Tex. 2011), and we must consider a
In his ﬁrst and second issues, Jordan argues that
provision's role in the broader statutory scheme,
the trial court erred by denying his motion to
20801, Inc. 1:. Parker, 249 S.W.3d 392, 396 (Tex.
dismiss as untimely. He argues that the 60—day
2008}
deadline for ﬁling a TCPA motion has not yet
begun to run because he was never served with 3. Analysis
the legal action and instead voluntarily appeared.
Alternatively, he argues that the 60—day deadline Jordan argues that his motion was timely because
was tolled because Hall was ordered to replead he was never served with the legal action and
and the supplemental petition was insufficient to instead voluntarily appeared. More speciﬁcally,
satisfy Hall’s pleading burden. Jordan argues that section 27.oo3(b)'s 60—day
deadline runs from the date of service and
A. Standard of Review and Applicable Law because he was never served, the 60—day clock
never began to run. Jordan argues that a
A party may ﬁle a motion to dismiss a legal action
voluntary appearance without service waives
based on, related to, or in response to a party‘s service of citation but not "service of {a1 legal
exercise of the right of free speech, right to action" under section 27.003(b), and Hall was
petitiori, or right of association. TEX. CIV. PRAC. required to serve him with the petition in order to
8.1 REM. CODE § 27.003(a). Section 27.00303]
trigger the 60—day deadline in section 27.003(b].
sets forth the deadline to file such a motion: "A
motion to dismiss a legal action under this section The Fourteenth Court of Appeals considered a
must be filed not later than the 60th day after the similar argument in Bcchorach v. Garcia , 485
date of service of the legal action." Id. § S.W.3d 600 (Tex. App—Houston [14th Dist]
27.003(b). The trial court may extend the time to 2016, no pet). Garcia sued Bacharach for slander
ﬁle a motion on a showing of good cause. Id.
Jordan 1'. Ha". 5m S.‘i\-‘.3d 194 ('l'ex. App. 201(3)

and libel, and Bacharach voluntarily appeared interpret section 27.003(b) as permitting a
and answered. voluntarily appearing defendant to ﬁle a TCPA
motion at any time, including several months or
[51o S.W.3d 198] years after answering, would run counter to the
purpose of the TCPA. See Ponlsen 455 S.W.3d at
,

Id. at 601. Eleven months after she answered, 197 ; Check , 438 S.W.3d at 837. Following
Bacharach moved to dismiss the suit pursuant to Bachomch , we hold that Jordan's 60—day
the TCPA, and the trial court denied the motion window in which to file his TCPA motion began to
as untimely. Id. at 601—02. run on the date on which he voluntarily appeared
by ﬁling an answer, October 30, 2015, and his
On appeal, Bacharach argued that the trial court deadline expired 60 days later. See Bucharach ,
erred by denying her motion as untimely because
435 S.W.3d at 602.
she had never been personally Served with the
suit and the 60—day deadline in section 27.00301) Jordan argues, however, that even if we conclude
never began to run. Id. at 602. The Fourteenth the TCPA's non-day clock started when he
Court of Appeals rejected this argument, holding voluntarily filed his answer, the deadline was
that Bacharach waived her right to formal service tolled when the triai court sustained his special
by voluntarily filing an answer, and this triggered exceptions on December 11, 2015. Jordan argues
the 60—day deadline in section 27.oo3_(b). See id. that the supplemental petition that Hall ﬁled on
(citing TEX. R. CIV. P. 121 ("An answer shall December 21, 2015, in response to the trial court's
constitute an appearance of the defendant so as to order sustaining the speciai exceptions, did not
dispense with the necessity for the issuance or cure the problems with Hall's pleading, and
service of citation upon him.")). therefore the TCPA dismissal deadline remains
tolled, matting his TCPA motion timely.
We agree with our sister court’s analysis in
Bochorach . It is well-settled that the purpose of Although an amended petition asserting claims
the TCPA is " ‘to allow a defendant early in the based upon new factual allegations may reset 3
lawsuit to dismiss claims that seek to inhibit a TCPA deadline as to the newlyeadded substance,
defendant's constitutional rights to petition, see James , 446 S.W.3d at 146, the deadline for a
speak freely, associate freely, and participate in TCPA motion is not reset when a plaintiff files an
"
government as permitted by law.’ Poulsen v. amended petition that adds no new claims and
Yarrell , 455 S.W.3d 192, 197 (Tex. App—Houston relies upon the same factual allegations
[1st Dist] 2014, no pet.) (quoting In re Estate of underlying an original petition. See Paulsen , 455
Check , 438 S.W.3d 829, 836 (Tex. App—San S.W.3d at 198. That is what happened here. The
Antonio 2014, no pet), superseded by statute an factUal allegation underlying Hall‘s causes of
other grounds as stated in Schlumherger Ltd. v. action in his original petition, and in his
Rutherford , 472 S.W.3d 881, 887—88 ('I‘ex. supplemental petition, is Jordan's purportedly
App.~—Houston [lst Dist] 2015, no pet.) ; see also illegal placement of the radio advertisement.
l’icicens v. Cordiu , 433 S.W.3d 179, 183 (Tex. Likewise, the claims asserted in the supplemental
App—Dallas 2014, no pet.) (’I‘CPA provides for petition are a subset of those
"expedited dismissal of unmeritorious suits”);
Sumnersett v. Jaiyeolo , 438 S.W.3d 84, 86 (Tex. [510 S.W.3d 199]
App—Corpus Christi 2013, pet. denied) (TCPA
"provides for the early dismissal of legal actions"). asserted in the original petition. Ac'cordingly,
It is also well-settled that a defendant may waive Jordan's 60—day deadline to ﬁle his TCPA motion
the requirement of service by voluntarily was not tolled or reset by the ﬁling of the
appearing. See TEX. R. CW. P. 121, 124 ; James 1:. supplemental petition or the trial court's order
Caikins , 446 S.W.3d 135, 142 (Tex. App.- granting special exceptions. See id. (plaintiffs
Houston [151 Dist] 2014, pet. denied). To amended petition relying on same factual
Jurtlun 1:. Hall. 5:” S.W.3d m4 t‘l‘ex. App. 2010}

allegations as original petition did not reset TCPA
deadline; defendant's subsequently-ﬁled TCPA
motion was therefore untimely); cf. James , 446
S.W.3d at 146 (claims added in amended petition
that were based upon substantively different
factual allegations than previous petitions were
subject to TCPA).

For the foregoing reasons, we hold that the trial
court did not err by denying Jordan's TCPA
motion as untimely. See Bachamch , 485 S.W.3d
at 602 ; Pauisen , 455 S.W.3d at 198.

We overrule Jordan's first and second issues.

Conclusion

We afﬁrm the trial court's order.
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.

Envelope ID: 65027751
Status as of 6/1/2022 2:41 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Christopher AKalis chriskalis@kalislaw.com 6/1/2022 2:09:27 PM SENT
Rita E.Slaten rslaten@meaderslaw.com 6/1/2022 2:09:27 PM SENT
Matt Lindner mlindner@kalislaw.com 6/1/2022 2:09:27 PM SENT
Cliff PRiley criley@dykema.com 6/1/2022 2:09:27 PM SENT
Christopher DKratovil ckratovil@dykema.com 6/1/2022 2:09:27 PM SENT
Kathy Lowery klowery@dykema.com 6/1/2022 2:09:27 PM SENT
Jennifer Schmitt jschmitt@dykema.com 6/1/2022 2:09:27 PM SENT

Associated Case Party: CREEKVIEW OWNERS ASSOCIATION

Name BarNumber Email TimestampSubmitted Status
Meaders & Alfaro eservice efiling@meaderslaw.com 6/1/2022 2:09:27 PM SENT
Kurt W.Meaders kmeaders@meaderslaw.com 6/1/2022 2:09:27 PM SENT
Alex Z.Gette alex.gette@meaderslawcom 6/1/2022 2:09:27 PM SENT

Associated Case Party: TIMOTHY G. PLE'I'I'A REVOCABLE TRUST

Name BarNumber Email Timestam pSubmitted Status
Pletta G.Pletta attorneypletta@hotmail.com 6/1/2022 2:09:27 PM SENT

Case Info

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TOBOLOWSKY, EMILY Track Judge’s New Case

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Document Filed Date

June 01, 2022

Case Filing Date

May 14, 2020

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Parties

BOGGESS, JEFF R Attorney for the Plaintiff
CREEKVIEW OWNERS ASSOCIATION Defendant
ELLIOTT, RICHARD Attorney for the Plaintiff
KRATOVIL, CHRISTOPHER D Attorney for the Defendant
LINDNER, MATTHEW P Attorney for the Plaintiff
MARTIN, J EDWIN Attorney for the Plaintiff
MEADERS, KURT WOOD Attorney for the Defendant
PLETTA, ANN H. Plaintiff
PLETTA, TIMOTHY G Plaintiff
PLETTA, TIMOTHY GERARD Attorney for the Plaintiff
SHERWOOD, JOHN CHARLES Attorney for the Plaintiff
SNYDER, GLENN R Attorney for the Plaintiff
SOO, CECILIA Defendant
SOO, KEN Defendant
TIMOTHY G. PLETTA REVOCABLE TRUST Plaintiff
Christopher Kalis Attorneys for Plaintiffs
Cliff Riley Attorney
Alexander Gette Attorneys for Defendants
Timothy Greene Attorney

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Letter,Correspondence: ANN H. PLETTA, et al vs. CECILIA SOO, et al

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