Preview
FILED
1/21/2022 4:40 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Margaret Thomas DEPUTY
CAUSE N0. DC-21-11479
RECOVERY FUNDING SERVICE, IN THE DISTRICT COURT
§§§§§§§§§§§§§§§§§§§
LLC, assignee of HATTON W.
SUMNERS FOUNDATION FOR
THE STUDY AND TEACHING OF
THE SCIENCE OF SELF-
GOVERNMENT, INC. d/b/a
SUMNERS FOUNDATION,
Plainttff,
V. 162‘” JUDICIAL DISTRICT
JAMES AMOS, JR., STEPHEN A.
BATMAN, WILLIAM D. GROSS,
DENNIS MCCUISTION, REAGAN
STEWART AND MICHAEL L.
WHALEN,
Defendants. DALLAS COUNTY, TEXAS
PLAINTIFF’S EMERGENCY MOTION FOR DISCOVERY TO RESPOND TO
DEFENDANTS’ TEX. CIV. PRAC. & REM. CODE 8 27 MOTION TO DISMISS AND
MOTION FOR SHORT CONTINUANCE
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Recovery Funding Service, LLC, assignee of Hatton W. Sumners
Foundation for the Study and Teaching of the Science of Self-Government, Inc. d/b/a Sumners
’
Foundation (“Plaintiff or “Sumners Foundation” herein) and files this, its Emergency Motion for
Discovery to Respond to Defendants’ TEX. CIV. PRAC. & REM. CODE § 27 Motion to Dismiss and
for Continuance of Defendants’ February 02, 2022 hearing and, for cause, would respectfully show
the Court as follows:
I.
FACTUAL BACKGROUND
1. Plaintiff realleges and incorporates herein by reference all allegations in Plaintiff s
Original Petition, Request for Disclosure, and Request for Production (the “Petition”).
FLAINTIFFS MOTION FOR DISCOVERY AND CONTINOANCE
#1001356 PAGEl OF7
2. The Defendants, as officers and/or directors of the National Center for Policy
Analysis (“NCPA”), violated their fiduciary duty owed to the Sumners Foundation by committing
fraudulent acts, providing fraudulent representations, and importantly, through their unauthorized
use of restricted funds granted by the Sumners Foundation. On June 23, 2020, the NCPA and the
Sumners Foundation entered into a Grant Agreement for the funding of a scholarship and
internship program, and lecture series (the “Agreement”). In part, the Agreement stipulated that
“the Foundation, at its discretion may require any portion of the grant unexpended at the
completion of the project or the end of the period to be returned to the Foundation.”
3. Pursuant to the Agreement, the Sumners Foundation provided a $375,000 grant to
the NCPA in or around July 2002, of which restricted $140,000 for an endowment fund purposed
for an internship program. Due to the NCPA officials’ mismanagement of restricted funds, failure
to enact proper financial controls, negligent hiring decisions, and resulting embezzlement of
NCPA flmds, the NCPA improperly comingled the Sumners Foundation’s grant, including its
restricted grant, with NCPA operating funds and effectively depleted the grant in its entirety.
4. The facts set forth in Plaintiff‘s Petition demonstrate Defendants knowingly used
the Sumners Foundation’s restricted grant funds for improper purposes and provided false
representations about the grant’s status, which Plaintiff relied on to its detriment.
II.
EMERGENCY MOTION FOR DISCOVERY
5. In response to the claims set forth in Plaintiff’s Petition, Defendants seek to dismiss
Plaintiff’s claims at the earliest stage of this litigation. Defendants filed a Motion to Dismiss
pursuant to the Texas Citizen Participation Act, TEX. CIV. PRAC. REM. CODE § 27.001 (the
“TCPA”) on December 30, 2021. On January 05, 2022, Defendants filed and served the Notice of
Hearing on their Chapter 27 Anti-SLAPP Motion to Dismiss, scheduling the hearing for February
PLA1NTIFFS MOTION FOR DISCOVERY AND CONTINUANCE
#1001356 PAGE20F7
02, 2022 at 10:30 am. After conferring with Defendants’ counsel on multiple occasions about
resolving the entire matter, the matter did not resolve.
6. As a preliminary matter, Plaintiff’s will argue that the TCPA is inapplicable to this
case. However, if this Court finds that the TCPA does apply, Plaintiff would likely be required to
produce prima-facie evidence of the elements of each challenged cause of action contained in the
Petition upon a hearing on the Anti-SLAPP Motion.
7. Section 27.006(b) of the TCPA authorizes the Court to order limited and specified
discovery concerning the statements and arguments Defendants made in their motion to dismiss.
Specifically, “[o]n a motion by a party or on the court’s own motion and on a showing of good
cause, the court may allow specified and limited discovery relevant to the motion. TEX. CIV. PRAC.
& REM. CODE § 27.006(b).
8. Texas courts hold discovery orders limited to discovering information necessary to
meet the minimum burden of establishing a prima facie case for the moving party’s causes of
action is proper. Discovery is relevant to the motion to dismiss if it seeks information related to
the allegations asserted in the motion. In re SPEX Group US LLC, No. 05-18-00208—CV, 2018
WL 1312407, at *4-5 (Tex. App—Dallas March 14, 2018, no pet. h.). Courts permit some merits-
based discovery seeking information to assist the non-movant in meeting its burden. Merits-based
discovery must be “specified and limited” because a prima facie standard generally “requires only
the minimum quantum of evidence necessary to support a rational inference that the allegation of
fact is true.” Id.; see In re E.I. DuPont de Nemours & Co., 136 S.W.3d 218, 223 (Tex. 2004) (orig.
proceeding).
9. At this very early stage of the litigation, Plaintiff merely holds general knowledge
of statements made regarding the incident, the police departments’ investigations, the results of
PLAINTIFFS MOTION FOR DISCOVERY AND CONTINUANCE
#1001356 PAGE3OF7
those investigations, including the finding Plaintiff did not engage in inappropriate conduct, and
some third-party accounts. To obtain crucial information from these non-parties and include such
findings in Plaintiff’s response to the Motion, additional formal discovery must be permitted.
10. Good cause exists in that Plaintiff will suffer a deprivation of substantial rights, if
this Court does not permit limited discovery, together with additional time to conduct such
discovery, in response to Defendants’ Motion to Dismiss. Further, this Court should permit the
discovery requested in order to decide this Motion by what the facts reveal, rather than what the
facts conceal.
11. As part of responding to the Motion to Dismiss, Plaintiff seeks very limited
discovery. More specifically, Plaintiff seeks:
l. Documents containing account balances, financial statements, ledgers, and/or
audits of NCPA finances immediately following the Sumners Foundation grant
until the NCPA’s liquidation;
2. Documents, communications, and ESI pertaining to the Defendants’ response to
the sexual misconduct scandal, their interactions and statements with press and/or
news outlets;
3. Documents, communications, and ESI pertaining to the NCPA officers’ and/or
board members’ decision to file the numerous NCPA lawsuits, including internal
meetings held to discuss filing such lawsuits, of which do not constitute privileged
information;
4. Documents, communications, and ESI pertaining to NCPA officers’ and/or board
members’ involvement with financial control and management;
5. Documents, communications, and ESI pertaining to the sale of NCPA assets at the
court-approved liquidation sale and contact with potential bidders prior to the sale;
and
6. To depose an individual and/or a corporate representative who, after the
Defendants’ document production, is deemed by the Plaintiff to hold information
relevant to the claims alleged in this case.
12. This discovery is necessary to adequately respond to Defendants’ Anti-SLAPP
Motion to Dismiss. The document requests will focus on the relationship between NCPA officers’
PLAINTIFFS MOTION FOR DISCOVERY AND CONTINUANCE
#1001356 PAGE4OF7
and/or directors’ and media outlets, Defendants’ duties and responsibilities as officers and/or
directors of the NCPA beginning from the inception of the Agreement until the NCPA dissolution.
This discovery is necessary to establish the Defendants’ knowledge of NCPA accounting practices
and record-keeping, assess Defendants’ internal communications pertaining to comingling of the
restricted funds with the NCPA operating account, and identify other individuals holding
knowledge relevant to the elements of Plaintiff’s claims.
13. The emergency discovery sought herein is material, and necessary: (1) to enable
Plaintiff to prepare for the response to the Defendants’ Motion to Dismiss; (2) to prevent the
destruction and disappearance of evidence; (3) to discovery and identify the extent of Defendants’
breach and misuse of Sumners Foundation’s funds; and (4) to discover the necessary proof.
14. Accordingly, Plaintiff requests specified and limited discovery in accordance with
section 27.006(b) of the TEXAS CIVIL PRACTICE & REMEDIES CODE. Plaintiff respectfully requests
that Defendants be required to produce responsive documents within a reasonable time and that
any depositions take place within a reasonable time after the production.
III.
MOTION FOR CONTINUAN CE
15. Plaintiff intends to use these discovery products in formulating a response to the
dismissal motion and will be unable to fully respond in the absence of these documents and
relevant information. Absent the opportunity to conduct limited discovery, Plaintiff will be
severely prejudiced. The current discovery period has not expired. Even with the utmost diligence,
there is simply insufficient time to conduct discovery and prepare a response with the current
setting. The evidence sought as to this case is not available from another source. Thus, Plaintiff
moves for a continuance of the current setting, to a date sufficient to allow Plaintiff to conduct the
PLAINTIFFS MOTION FOR DISCOVERY AND CONTINUANCE
#1001356 PAGE50F7
discovery necessary and adequately prepare its response to the Motion to Dismiss. This motion is
not meant for delay, but so that justice may be done.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that the Court grant the relief
requested herein, and for such other and further relief, in law or in equity, to which Plaintiff may
be justly entitled.
Respectfully submitted,
FRIEDMAN & FEIGER, L.L.P.
/s/ Jason H. Friedman
By:
Lawrence J. Friedman
State Bar No. 07469300
lfriedman@fflawoff1ce.com
Jason H. Friedman
State Bar No. 24059784
jason@fflawoffice.com
ATTORNEYS FOR PLAINTIFF
CERTIFICATE 0F SERVICE
I, the undersigned, hereby certify that on January 21, 2022, a true and correct copy of the
foregoing has been served on all counsel of record via E-Service pursuant to Rule 21 of the TEXAS
RULES 0F CIVIL PROCEDURE.
/s/Jas0n H. Friedman
Attorney
CERTIFICATE OF CONFERENCE
I, the undersigned attorney, hereby certify to the Court that I have conferred with opposing
counsel in an effort to resolve the issues contained in this motion without the necessity of court
PLAINTIFFS MOTION FOR DISCOVERY AND CONTINUANCE
#1001356 PAGE6OF7
intervention, and opposing counsel has indicated that he does not oppose the motion in principle,
but opposes the scope of discovery sought by the movant.
Certified to the day of January 21, 2022
/s/Kaitlvn M Coker
Attorney for Movant
PLAINTIFFS MOTION FOR DISCOVERY AND CONTINUANCE
#1001356 PAGE7OF7
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: 61050923
Status as of 1/24/2022 7:38 AM CST
Associated Case Party: RECOVERY FUNDING SERVICE, LLC,
Name BarNumber Email TimestampSubmitted Status
Jason HFriedman jhfriedman@filawoffice.com 1/21/2022 4:40:01 PM SENT
Jeff O'Dell jodel|@fflawoffice.com 1/21/2022 4:40:01 PM SENT
Stacy Morrison smorrison@fflawoffice.com 1/21/2022 4:40:01 PM SENT
Jossette Griffin jgriffin@fflawoffice.com 1/21/2022 4:40:01 PM SENT
Mariam Alghaziani malghaziani@fflawoffice.com 1/21/2022 4:40:01 PM ERROR
Associated Case Party: JAMES AMOS
Name BarNumber Email TimestampSubmitted Status
J. ReidBurley rburley@bellnunnally.com 1/21/2022 4:40:01 PM SENT
R. HeathCheek hcheek@bellnunnally.com 1/21/2022 4:40:01 PM SENT
Associated Case Party: REAGAN STEWART
Name BarNumber Email TimestampSubmitted Status
J. ReidBurley rburley@bellnunnally.com 1/21/2022 4:40:01 PM SENT
R. HeathCheek hcheek@bellnunnally.com 1/21/2022 4:40:01 PM SENT
Associated Case Party: MICHAELL.WHALEN
Name BarNumber Email TimestampSubmitted Status
J. ReidBurley rburley@bellnunnally.com 1/21/2022 4:40:01 PM SENT
R. HeathCheek hcheek@bellnunnally.com 1/21/2022 4:40:01 PM SENT
Case Contacts
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: 61050923
Status as of 1/24/2022 7:38 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
JASON HFRIEDMAN Jason@fflawoffice.com 1/21/2022 4:40:01 PM SENT
Nancy Blum nblum@bellnunnally.com 1/21/2022 4:40:01 PM SENT
Kaitlyn M.Coker kcoker@fflawoffice.com 1/21/2022 4:40:01 PM SENT
Associated Case Party: STEPHENA.BATMAN
Name BarNumber Email TimestampSubmitted Status
H. N. Cunningham 5246900 hnciii@aol.com 1/21/2022 4:40:01 PM SENT
Associated Case Party: WILLIAMD.GROSS
Name BarNumber Email TimestampSubmitted Status
Stephen Kennedy skennedy@saklaw.net 1/21/2022 4:40:01 PM SENT
Joel Paniagua admin@saklaw.net 1/21/2022 4:40:01 PM SENT
Preview
FILED 1/21/2022 4:40 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Margaret Thomas DEPUTY CAUSE N0. DC-21-11479 RECOVERY FUNDING SERVICE, IN THE DISTRICT COURT §§§§§§§§§§§§§§§§§§§ LLC, assignee of HATTON W. SUMNERS FOUNDATION FOR THE STUDY AND TEACHING OF THE SCIENCE OF SELF- GOVERNMENT, INC. d/b/a SUMNERS FOUNDATION, Plainttff, V. 162‘” JUDICIAL DISTRICT JAMES AMOS, JR., STEPHEN A. BATMAN, WILLIAM D. GROSS, DENNIS MCCUISTION, REAGAN STEWART AND MICHAEL L. WHALEN, Defendants. DALLAS COUNTY, TEXAS PLAINTIFF’S EMERGENCY MOTION FOR DISCOVERY TO RESPOND TO DEFENDANTS’ TEX. CIV. PRAC. & REM. CODE 8 27 MOTION TO DISMISS AND MOTION FOR SHORT CONTINUANCE TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Recovery Funding Service, LLC, assignee of Hatton W. Sumners Foundation for the Study and Teaching of the Science of Self-Government, Inc. d/b/a Sumners ’ Foundation (“Plaintiff or “Sumners Foundation” herein) and files this, its Emergency Motion for Discovery to Respond to Defendants’ TEX. CIV. PRAC. & REM. CODE § 27 Motion to Dismiss and for Continuance of Defendants’ February 02, 2022 hearing and, for cause, would respectfully show the Court as follows: I. FACTUAL BACKGROUND 1. Plaintiff realleges and incorporates herein by reference all allegations in Plaintiff s Original Petition, Request for Disclosure, and Request for Production (the “Petition”). FLAINTIFFS MOTION FOR DISCOVERY AND CONTINOANCE #1001356 PAGEl OF7 2. The Defendants, as officers and/or directors of the National Center for Policy Analysis (“NCPA”), violated their fiduciary duty owed to the Sumners Foundation by committing fraudulent acts, providing fraudulent representations, and importantly, through their unauthorized use of restricted funds granted by the Sumners Foundation. On June 23, 2020, the NCPA and the Sumners Foundation entered into a Grant Agreement for the funding of a scholarship and internship program, and lecture series (the “Agreement”). In part, the Agreement stipulated that “the Foundation, at its discretion may require any portion of the grant unexpended at the completion of the project or the end of the period to be returned to the Foundation.” 3. Pursuant to the Agreement, the Sumners Foundation provided a $375,000 grant to the NCPA in or around July 2002, of which restricted $140,000 for an endowment fund purposed for an internship program. Due to the NCPA officials’ mismanagement of restricted funds, failure to enact proper financial controls, negligent hiring decisions, and resulting embezzlement of NCPA flmds, the NCPA improperly comingled the Sumners Foundation’s grant, including its restricted grant, with NCPA operating funds and effectively depleted the grant in its entirety. 4. The facts set forth in Plaintiff‘s Petition demonstrate Defendants knowingly used the Sumners Foundation’s restricted grant funds for improper purposes and provided false representations about the grant’s status, which Plaintiff relied on to its detriment. II. EMERGENCY MOTION FOR DISCOVERY 5. In response to the claims set forth in Plaintiff’s Petition, Defendants seek to dismiss Plaintiff’s claims at the earliest stage of this litigation. Defendants filed a Motion to Dismiss pursuant to the Texas Citizen Participation Act, TEX. CIV. PRAC. REM. CODE § 27.001 (the “TCPA”) on December 30, 2021. On January 05, 2022, Defendants filed and served the Notice of Hearing on their Chapter 27 Anti-SLAPP Motion to Dismiss, scheduling the hearing for February PLA1NTIFFS MOTION FOR DISCOVERY AND CONTINUANCE #1001356 PAGE20F7 02, 2022 at 10:30 am. After conferring with Defendants’ counsel on multiple occasions about resolving the entire matter, the matter did not resolve. 6. As a preliminary matter, Plaintiff’s will argue that the TCPA is inapplicable to this case. However, if this Court finds that the TCPA does apply, Plaintiff would likely be required to produce prima-facie evidence of the elements of each challenged cause of action contained in the Petition upon a hearing on the Anti-SLAPP Motion. 7. Section 27.006(b) of the TCPA authorizes the Court to order limited and specified discovery concerning the statements and arguments Defendants made in their motion to dismiss. Specifically, “[o]n a motion by a party or on the court’s own motion and on a showing of good cause, the court may allow specified and limited discovery relevant to the motion. TEX. CIV. PRAC. & REM. CODE § 27.006(b). 8. Texas courts hold discovery orders limited to discovering information necessary to meet the minimum burden of establishing a prima facie case for the moving party’s causes of action is proper. Discovery is relevant to the motion to dismiss if it seeks information related to the allegations asserted in the motion. In re SPEX Group US LLC, No. 05-18-00208—CV, 2018 WL 1312407, at *4-5 (Tex. App—Dallas March 14, 2018, no pet. h.). Courts permit some merits- based discovery seeking information to assist the non-movant in meeting its burden. Merits-based discovery must be “specified and limited” because a prima facie standard generally “requires only the minimum quantum of evidence necessary to support a rational inference that the allegation of fact is true.” Id.; see In re E.I. DuPont de Nemours & Co., 136 S.W.3d 218, 223 (Tex. 2004) (orig. proceeding). 9. At this very early stage of the litigation, Plaintiff merely holds general knowledge of statements made regarding the incident, the police departments’ investigations, the results of PLAINTIFFS MOTION FOR DISCOVERY AND CONTINUANCE #1001356 PAGE3OF7 those investigations, including the finding Plaintiff did not engage in inappropriate conduct, and some third-party accounts. To obtain crucial information from these non-parties and include such findings in Plaintiff’s response to the Motion, additional formal discovery must be permitted. 10. Good cause exists in that Plaintiff will suffer a deprivation of substantial rights, if this Court does not permit limited discovery, together with additional time to conduct such discovery, in response to Defendants’ Motion to Dismiss. Further, this Court should permit the discovery requested in order to decide this Motion by what the facts reveal, rather than what the facts conceal. 11. As part of responding to the Motion to Dismiss, Plaintiff seeks very limited discovery. More specifically, Plaintiff seeks: l. Documents containing account balances, financial statements, ledgers, and/or audits of NCPA finances immediately following the Sumners Foundation grant until the NCPA’s liquidation; 2. Documents, communications, and ESI pertaining to the Defendants’ response to the sexual misconduct scandal, their interactions and statements with press and/or news outlets; 3. Documents, communications, and ESI pertaining to the NCPA officers’ and/or board members’ decision to file the numerous NCPA lawsuits, including internal meetings held to discuss filing such lawsuits, of which do not constitute privileged information; 4. Documents, communications, and ESI pertaining to NCPA officers’ and/or board members’ involvement with financial control and management; 5. Documents, communications, and ESI pertaining to the sale of NCPA assets at the court-approved liquidation sale and contact with potential bidders prior to the sale; and 6. To depose an individual and/or a corporate representative who, after the Defendants’ document production, is deemed by the Plaintiff to hold information relevant to the claims alleged in this case. 12. This discovery is necessary to adequately respond to Defendants’ Anti-SLAPP Motion to Dismiss. The document requests will focus on the relationship between NCPA officers’ PLAINTIFFS MOTION FOR DISCOVERY AND CONTINUANCE #1001356 PAGE4OF7 and/or directors’ and media outlets, Defendants’ duties and responsibilities as officers and/or directors of the NCPA beginning from the inception of the Agreement until the NCPA dissolution. This discovery is necessary to establish the Defendants’ knowledge of NCPA accounting practices and record-keeping, assess Defendants’ internal communications pertaining to comingling of the restricted funds with the NCPA operating account, and identify other individuals holding knowledge relevant to the elements of Plaintiff’s claims. 13. The emergency discovery sought herein is material, and necessary: (1) to enable Plaintiff to prepare for the response to the Defendants’ Motion to Dismiss; (2) to prevent the destruction and disappearance of evidence; (3) to discovery and identify the extent of Defendants’ breach and misuse of Sumners Foundation’s funds; and (4) to discover the necessary proof. 14. Accordingly, Plaintiff requests specified and limited discovery in accordance with section 27.006(b) of the TEXAS CIVIL PRACTICE & REMEDIES CODE. Plaintiff respectfully requests that Defendants be required to produce responsive documents within a reasonable time and that any depositions take place within a reasonable time after the production. III. MOTION FOR CONTINUAN CE 15. Plaintiff intends to use these discovery products in formulating a response to the dismissal motion and will be unable to fully respond in the absence of these documents and relevant information. Absent the opportunity to conduct limited discovery, Plaintiff will be severely prejudiced. The current discovery period has not expired. Even with the utmost diligence, there is simply insufficient time to conduct discovery and prepare a response with the current setting. The evidence sought as to this case is not available from another source. Thus, Plaintiff moves for a continuance of the current setting, to a date sufficient to allow Plaintiff to conduct the PLAINTIFFS MOTION FOR DISCOVERY AND CONTINUANCE #1001356 PAGE50F7 discovery necessary and adequately prepare its response to the Motion to Dismiss. This motion is not meant for delay, but so that justice may be done. PRAYER WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that the Court grant the relief requested herein, and for such other and further relief, in law or in equity, to which Plaintiff may be justly entitled. Respectfully submitted, FRIEDMAN & FEIGER, L.L.P. /s/ Jason H. Friedman By: Lawrence J. Friedman State Bar No. 07469300 lfriedman@fflawoff1ce.com Jason H. Friedman State Bar No. 24059784 jason@fflawoffice.com ATTORNEYS FOR PLAINTIFF CERTIFICATE 0F SERVICE I, the undersigned, hereby certify that on January 21, 2022, a true and correct copy of the foregoing has been served on all counsel of record via E-Service pursuant to Rule 21 of the TEXAS RULES 0F CIVIL PROCEDURE. /s/Jas0n H. Friedman Attorney CERTIFICATE OF CONFERENCE I, the undersigned attorney, hereby certify to the Court that I have conferred with opposing counsel in an effort to resolve the issues contained in this motion without the necessity of court PLAINTIFFS MOTION FOR DISCOVERY AND CONTINUANCE #1001356 PAGE6OF7 intervention, and opposing counsel has indicated that he does not oppose the motion in principle, but opposes the scope of discovery sought by the movant. Certified to the day of January 21, 2022 /s/Kaitlvn M Coker Attorney for Movant PLAINTIFFS MOTION FOR DISCOVERY AND CONTINUANCE #1001356 PAGE7OF7 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: 61050923 Status as of 1/24/2022 7:38 AM CST Associated Case Party: RECOVERY FUNDING SERVICE, LLC, Name BarNumber Email TimestampSubmitted Status Jason HFriedman jhfriedman@filawoffice.com 1/21/2022 4:40:01 PM SENT Jeff O'Dell jodel|@fflawoffice.com 1/21/2022 4:40:01 PM SENT Stacy Morrison smorrison@fflawoffice.com 1/21/2022 4:40:01 PM SENT Jossette Griffin jgriffin@fflawoffice.com 1/21/2022 4:40:01 PM SENT Mariam Alghaziani malghaziani@fflawoffice.com 1/21/2022 4:40:01 PM ERROR Associated Case Party: JAMES AMOS Name BarNumber Email TimestampSubmitted Status J. ReidBurley rburley@bellnunnally.com 1/21/2022 4:40:01 PM SENT R. HeathCheek hcheek@bellnunnally.com 1/21/2022 4:40:01 PM SENT Associated Case Party: REAGAN STEWART Name BarNumber Email TimestampSubmitted Status J. ReidBurley rburley@bellnunnally.com 1/21/2022 4:40:01 PM SENT R. HeathCheek hcheek@bellnunnally.com 1/21/2022 4:40:01 PM SENT Associated Case Party: MICHAELL.WHALEN Name BarNumber Email TimestampSubmitted Status J. ReidBurley rburley@bellnunnally.com 1/21/2022 4:40:01 PM SENT R. HeathCheek hcheek@bellnunnally.com 1/21/2022 4:40:01 PM SENT Case Contacts 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: 61050923 Status as of 1/24/2022 7:38 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status JASON HFRIEDMAN Jason@fflawoffice.com 1/21/2022 4:40:01 PM SENT Nancy Blum nblum@bellnunnally.com 1/21/2022 4:40:01 PM SENT Kaitlyn M.Coker kcoker@fflawoffice.com 1/21/2022 4:40:01 PM SENT Associated Case Party: STEPHENA.BATMAN Name BarNumber Email TimestampSubmitted Status H. N. Cunningham 5246900 hnciii@aol.com 1/21/2022 4:40:01 PM SENT Associated Case Party: WILLIAMD.GROSS Name BarNumber Email TimestampSubmitted Status Stephen Kennedy skennedy@saklaw.net 1/21/2022 4:40:01 PM SENT Joel Paniagua admin@saklaw.net 1/21/2022 4:40:01 PM SENT