Order: T.H. Trust vs Robert G Pate and Judy K Pate

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                                NO. 17-DCV-243655

DAVID H. HAMILTON, AS TRUSTEE                            IN THE DISTRICT COURT
OF T. H. TRUST
Plaintiff and Counter-Defendant,

Vv.

ROBERT G. PATE AND JUDY K. PATE                          434TH JUDICIAL DISTRICT
Defendants and Counter-Plaintiffs

Vv.

GEORGE M. BISHOP
Cross-Defendant,                                         OF FORT BEND COUNTY, TEXAS



  MOTION FOR CLARIFICATION OF ORDER GRANTING DEFENDANT’S MOTION
      FOR SUMMARY JUDGMENT AND FOR ENTRY OF FINAL JUDGMENT

TO THE HONORABLE JUDGE OF SAID COURT:

          On February 4, 2022, the Court considered the Motion for Summary Judgment filed by

Robert G. Pate and Judy K. Pate (“Defendants”) which requested that the Court entered Summary

Judgment in favor of Defendants on all claims of the Plaintiff against the Defendants as well as

Summary Judgment in favor of the Defendants on all counterclaims and cross-claims against the

Plaintiff David H. Hamilton, as Trustee of T.H. Trust and the Counter-Defendant George M.

Bishop.    The Court further considered all claims presented in the various pleadings against the

Defendants by George M. Bishop, and declined to grant Bishop’s motion for summary judgment

regarding such claims.

          The Court signed its Order Granting Defendant’s Motion for Summary Judgment on

February 4, 2022, granting the motion in part and made certain findings.
The effect of the Court’s Order was to enter an Interlocutory Order granting the Defendants

substantially all of their requests in their Motion, except for Defendants’   requests for affirmative

recovery of damages, attorney’s fees, and similar claims.

       Defendants request the Court to enter a Final Judgment consistent with its ruling on

February 4, 2022, and that it additionally specifically deny Defendants’ various requests for relief

against the Plaintiffs and Bishop’s Motion for Summary Judgment against the Defendants.

       Defendants submit herewith a proposed form of Final Judgment, by the terms of which the

Court confirms the denial of certain claims by Defendants against the Plaintiffs and further clearly

denies Bishop’s counterclaims against the Defendants, resulting in a Final Judgment.

        Wherefore, Defendants request the Court to sign the attached Final Judgment, including

Order Clarifying Order Granting Defendants Motion for Summary Judgment.


                                               Respectfully submitted,


                                               By: /s/Russell C. Jones
                                                     Russell C. Jones
                                                     Texas Bar No. 10954300
                                                     Email: rjones@jonesattorneys.com
                                                     407 Julie Rivers Drive
                                                     Sugar Land, TX 77478
                                                     Tel. (281) 242-8100
                                                     Fax. (281) 242-7474
                                                     Attorney for Defendants
                                                     Robert G. Pate and Judy K. Pate
CERTIFICATE OF SERVICE

I certify that on August 1‘', 2022 a true and correct copy of Motion for Clarification of Order
Granting Defendants Motion For Summary Judgment And For Entry Of Final Judgment was
served on George M. Bishop and Jeffrey R. Vaughan electronically through the electronic filing
manager.




                                            /s/Russell C. Jones
                                            Russell C. Jones