Preview
FILED
3/10/2022 7:53 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Loaidi Grove DEPUTY
DC-21-03339
BLUE MOUNTAIN PROPERTY * In the District Court
VENTURES LLC *
*
V. * 298th Judicial District
*
BESSIE HARRISON * Dallas County, Texas
DEFENDANT’S OBJECTION TO PLAINTIFF’S
MOTION FOR SUMMARY JUDGMENT FOR VIOLATION OF COURT ORDER
T0 THE HONORABLE JUDGE 0F SAID COURT:
COMES NOW, Defendant Bessie Harrison, by and through her attorney of
record, Robert M. Clark, in the above-entitled and numbered cause and makes and files this
objection in opposition to Plaintiff’s appendix to the Motion for Traditional and No-Evidence
Summary Judgment, which includes a 13 page motion and a separate 42 page appendix totaling
55 pages, as follows:
I. ARGUMENT
The Plaintiff and its attorneys should follow the court’s local rules, including the
length of the motion’s appendix, which have been approved by the Texas Supreme Court. The
Amended Local Rules of Dallas County dated April 6, 2020 (“General Order”), enacts a 25-page
limit to an appendix filed in support of any Motion or Brief. See General Order. It is dated April
6, 2020. Furthermore, all motions must be sequentially numbered pursuant to Rule 2.04 of the
Dallas County Local Civil Rules. The Appendix to Plaintiffs Response is not paginated in a
single numbering list, and, therefore, is also objected to for that reason.
PRAYER
No compelling reasons exist for the long motion and appendix. For these reasons,
Defendant requests that the Court follow its rules and grant this objection by striking Plaintiff’s
Defendant’s Objection to Plaintiff’ s Motion for Summary Judgment for Violation of Court Order - Page l of 2
Motion for Summary Judgment. An appropriate sanction would be to dismiss the motion for
summary judgment and not allowing its resetting or refiling.
Respectfully submitted,
EDDLEMAN & CLARK
4627 North Central Expressway
Knox Central Place, Suite 2000
Dallas, Texas 75205-4022
Phone 214.528.2400
Fax 214.528.2434
RMC@RobertMClark.net
from M
ROBERT M. CLARK
State Bar No. 04298200
Attorney for Defendant
Certificate of Service
I certify that a true copy of the above was served on counsel for Plaintiff Landon Thompson at the
Meazell Firm, 1400 Gables Court, Plano, TX 75075, Fax 972.398.8488,
l.thompson@meazellfirm.com in accordance with Rule 21a of the Texas Rules of Civil Procedure
on the 10th day of March, 2022.
WM. W
Robert M. Clark
Defendant’s Objection to Plaintiffs Motion for Summary Judgment for Violation of Court Order - Page 2 of 2
IN THE CIVIL DISTRICT COURTS
of the
STATE OF TEXAS
SITTING IN DALLAS COUNTY
GENERALQRDER
No Motion or Brief filed with the Court may exceed 25 one-
sided pages in length. Only one appendix, also limited to 25
one-sided pages in length may be filed supporting any
Motion or Brief. The use of any font less than 12 point, or
margins less than 1” on each side of a page is hereby
prohibited. Additionally, the use of reduced, multiple pages
(i.e.: Min-u-script) is hereby prohibited.
Permission to file a brief in excess of these page limitations
may be granted by the Presiding Judge of any particular
Court upon a showing of compelling reasons.
It is so ORDERED
Signed this _61h_ day of April, 2020.
Q“ Z. M $.22“ ,—
The Hon. Eric V. Moyé, The Hon. Bonnie Goldstein,
Presiding Judge, 14th District Court Presiding Judge, 44th District Court
The Hon. Martin Hoffman, The Hon. Staci Williams,
Presiding Judge, 68th District Court Presiding Judge, 101st District Court
Exhibit A
-
a
u u
e l fl ED E (r nee
The Hon. Tonya Parker, The Hon. Dale Tillery,
Presiding Judge, 116h District Court Presiding Judge, 134th District Court
The Hon. Aiesha Redmond, The Hon. Maricela Moore,
Presiding Judge, 160th District Court Presiding Judge, 162nd District Court
E.
The Hon. Gena Slaughter The Hon. Craig Smith,
Presiding Judge, 191st District Court Presiding Judge, 192nd District Court
The Hon. Bridgett Whitmore, The Hon. Emily Tobolowsky,
Presiding Judge, 193rd District Court Presiding Judge, 298th District Court
Exhibit A
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.
Robert Clark on behalf of Robert Clark
Bar No. 4298200
office@robertmclark.net
Envelope ID: 62473029
Status as of 3/10/2022 8:10 AM CST
Associated Case Party: BLUE MOUNTAIN PROPERTY VENTURES, LLC
Name BarN umber Email TimestampSubmitted Status
John Meazell j.meazell@meazellfirm.com 3/10/2022 7:53:59 AM SENT
Skyler N.Harrigan s.harrigan@meazellfirm.com 3/10/2022 7:53:59 AM SENT
Landon H.Thompson |.thompson@meazellfirm.com 3/10/2022 7:53:59 AM SENT
Preview
FILED 3/10/2022 7:53 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Loaidi Grove DEPUTY DC-21-03339 BLUE MOUNTAIN PROPERTY * In the District Court VENTURES LLC * * V. * 298th Judicial District * BESSIE HARRISON * Dallas County, Texas DEFENDANT’S OBJECTION TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT FOR VIOLATION OF COURT ORDER T0 THE HONORABLE JUDGE 0F SAID COURT: COMES NOW, Defendant Bessie Harrison, by and through her attorney of record, Robert M. Clark, in the above-entitled and numbered cause and makes and files this objection in opposition to Plaintiff’s appendix to the Motion for Traditional and No-Evidence Summary Judgment, which includes a 13 page motion and a separate 42 page appendix totaling 55 pages, as follows: I. ARGUMENT The Plaintiff and its attorneys should follow the court’s local rules, including the length of the motion’s appendix, which have been approved by the Texas Supreme Court. The Amended Local Rules of Dallas County dated April 6, 2020 (“General Order”), enacts a 25-page limit to an appendix filed in support of any Motion or Brief. See General Order. It is dated April 6, 2020. Furthermore, all motions must be sequentially numbered pursuant to Rule 2.04 of the Dallas County Local Civil Rules. The Appendix to Plaintiffs Response is not paginated in a single numbering list, and, therefore, is also objected to for that reason. PRAYER No compelling reasons exist for the long motion and appendix. For these reasons, Defendant requests that the Court follow its rules and grant this objection by striking Plaintiff’s Defendant’s Objection to Plaintiff’ s Motion for Summary Judgment for Violation of Court Order - Page l of 2 Motion for Summary Judgment. An appropriate sanction would be to dismiss the motion for summary judgment and not allowing its resetting or refiling. Respectfully submitted, EDDLEMAN & CLARK 4627 North Central Expressway Knox Central Place, Suite 2000 Dallas, Texas 75205-4022 Phone 214.528.2400 Fax 214.528.2434 RMC@RobertMClark.net from M ROBERT M. CLARK State Bar No. 04298200 Attorney for Defendant Certificate of Service I certify that a true copy of the above was served on counsel for Plaintiff Landon Thompson at the Meazell Firm, 1400 Gables Court, Plano, TX 75075, Fax 972.398.8488, l.thompson@meazellfirm.com in accordance with Rule 21a of the Texas Rules of Civil Procedure on the 10th day of March, 2022. WM. W Robert M. Clark Defendant’s Objection to Plaintiffs Motion for Summary Judgment for Violation of Court Order - Page 2 of 2 IN THE CIVIL DISTRICT COURTS of the STATE OF TEXAS SITTING IN DALLAS COUNTY GENERALQRDER No Motion or Brief filed with the Court may exceed 25 one- sided pages in length. Only one appendix, also limited to 25 one-sided pages in length may be filed supporting any Motion or Brief. The use of any font less than 12 point, or margins less than 1” on each side of a page is hereby prohibited. Additionally, the use of reduced, multiple pages (i.e.: Min-u-script) is hereby prohibited. Permission to file a brief in excess of these page limitations may be granted by the Presiding Judge of any particular Court upon a showing of compelling reasons. It is so ORDERED Signed this _61h_ day of April, 2020. Q“ Z. M $.22“ ,— The Hon. Eric V. Moyé, The Hon. Bonnie Goldstein, Presiding Judge, 14th District Court Presiding Judge, 44th District Court The Hon. Martin Hoffman, The Hon. Staci Williams, Presiding Judge, 68th District Court Presiding Judge, 101st District Court Exhibit A - a u u e l fl ED E (r nee The Hon. Tonya Parker, The Hon. Dale Tillery, Presiding Judge, 116h District Court Presiding Judge, 134th District Court The Hon. Aiesha Redmond, The Hon. Maricela Moore, Presiding Judge, 160th District Court Presiding Judge, 162nd District Court E. The Hon. Gena Slaughter The Hon. Craig Smith, Presiding Judge, 191st District Court Presiding Judge, 192nd District Court The Hon. Bridgett Whitmore, The Hon. Emily Tobolowsky, Presiding Judge, 193rd District Court Presiding Judge, 298th District Court Exhibit A 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. Robert Clark on behalf of Robert Clark Bar No. 4298200 office@robertmclark.net Envelope ID: 62473029 Status as of 3/10/2022 8:10 AM CST Associated Case Party: BLUE MOUNTAIN PROPERTY VENTURES, LLC Name BarN umber Email TimestampSubmitted Status John Meazell j.meazell@meazellfirm.com 3/10/2022 7:53:59 AM SENT Skyler N.Harrigan s.harrigan@meazellfirm.com 3/10/2022 7:53:59 AM SENT Landon H.Thompson |.thompson@meazellfirm.com 3/10/2022 7:53:59 AM SENT