Preview
Electronically Filed
9/22/2023 2:21 PM
Hidalgo County District Clerks
Reviewed By: Rachel Bueno
CAUSE NO. C-2316-23-H
PATRICIA NIELSEN, ET AL § IN THE DISTRICT COURT
Plaintiffs, §
§
v. § 389TH JUDICIAL DISTRICT
§
ANTHONY JOHNSON, ET AL, §
Defendants. § HIDALGO COUNTY, TEXAS
DEFENDANT ANTHONY JOHNSON’S
MOTION TO ENFORCE RULE 11 AGREEMENT
INTRODUCTION
On June 29th, 2023, this Court held a Hearing on Plaintiffs’ Application for Temporary
Injunction (“the Hearing”) in connection with Cause No. C-2316-23-H; Patricia Nielsen, et al v.
Anthony Johnson, et al; In the 389th Judicial District Court of Hidalgo County, Texas. A copy of the
hearing transcript (“Hearing Transcript”) is attached as Exhibit A. Stephen Leas was present on behalf
of the Plaintiff, Patricia Nielsen and Sarah Cowen and Dan Worthington were present on behalf of
the Defendant, Anthony Johnson. The Parties reached an agreement at the hearing and dictated the
terms of the agreement into the record. See Exhibit A, Hearing Transcript at page 4, ll 6-12.
Despite the Parties reaching an agreement, Plaintiff refuses to fulfill her obligations under the
agreement and it has become necessary to seek Court intervention.
AGREEMENT
At the Hearing, in open court, as evidenced by the Hearing Transcript, the Parties agreed to a
Rule 11 Agreement with the following terms:
A. Non-Destruction of Emails:
MR. WORTHINGTON: Your Honor, the parties have agreed to meet in approximately two
weeks to work through the issues that are alleged in the suit. The parties have agreed that
neither party will destroy documents, e-mails, anything like that. We'll preserve all the evidence
we have. The plaintiff --
THE COURT: What documents would those be? So I understand what you're talking about.
See Hearing Transcript at page 5, ll 12-19.
MS. COWEN: There's a d/b/a under which multiple companies operate, Your Honor.
THE COURT: I want to make sure we understand -- you're going to put everything on the
record. What businesses are you not destroying documents?
MS. COWEN: All of the PEOs that operate under the d/b/a Corporate Solutions; and there's
Electronically Filed
9/22/2023 2:21 PM
Hidalgo County District Clerks
Reviewed By: Rachel Bueno
multiple of them. And I don't know that we're prepared to list all of them, but there's no
disagreement between the parties as to which PEOs --
THE COURT: Anything that deals with Corporate Solutions?
MR. LEAS: Yes, Your Honor.
MR. WORTHINGTON: Yes, Your Honor.
MS. COWEN: That's the big thing that's being unwound right now.
THE COURT: Any business, anything that deals with Corporate Solutions?
MR. WORTHINGTON: Yes, Your Honor.
MR. LEAS: Yes, ma'am.
THE COURT: Okay.
See Hearing Transcript at page 6, ll 3-24.
B. Email Accounts:
MS. COWEN: Yes. They've also -- they've agreed -- the plaintiff has agreed to give the
defendant access to his e-mail account that was cut off earlier.
THE COURT: Which e-mail account?
MR. WORTHINGTON: Your Honor, we have – there's five or six e-mail accounts. I don't
have them here. We'll get them with the plaintiff, Your Honor. I apologize.
THE COURT: Write them down so you can put it on the record. What e-mail accounts?
MS. COWEN: Your Honor, as part of the – the unwinding that's already taken place, several
employees that worked for both parties now have gone to work solely for Mr. Anthony
Johnson. They all have e-mail addresses that are their initials at corpsolpeo.com -- C-O-R-P-
S-O-L-P-E-O dot com.
See Id, Hearing Transcript at page 7, ll 1-20.
PLAINTIFF HAS FAILED TO COMPLY WITH THE AGREEMENT
Following the Hearing, Defendant’s counsel sent Plaintiff’s counsel an executed copy of the
Rule 11 Agreement that outlined the terms of the agreement and set out the identification of the email
addresses in issue with specificity. See Exhibit B, Rule 11 Agreement. Plaintiff has refused to execute
the memorialized agreement, has failed to comply with the agreement to meet in person to work
through the issues involved in unwinding the business, and has failed to comply with the agreement
to provide access to business email accounts set out in the record above.
ARGUMENT & AUTHORITIES
Texas Rule of Civil Procedure 11 provides that, “[u]nless otherwise provided in these rules,
no agreement between attorneys or parties touching any suit pending will be enforced unless it be in
writing, signed and filed with the papers as part of the record, or unless it be made in open court and
entered of record.” Tex. R. Civ. P. 11. Agreements entered under Rule 11 “are contracts relating to
litigation, and thus we construe them under the same rules as a contract.” Shamrock Psychiatric Clinic,
P.A. v. Tex. Dep't of Health & Human Servs., 540 S.W.3d 553, 560 (Tex. 2018) (per curiam). “We do
not give a Rule 11 agreement greater effect than the parties intended.” Id. at 560–61. Further, if the
agreement can be given a certain or definite legal meaning or interpretation, it is not ambiguous, and
2
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Hidalgo County District Clerks
Reviewed By: Rachel Bueno
we construe it as a matter of law. Id. at 561 (citing Coker v. Coker, 650 S.W.2d 391, 393 (Tex. 1983)).
See In re Philips, No. 13-21-00312-CV, 2022 WL 354513, at *5–6 (Tex. App. Feb. 7, 2022).
To be effective, a Rule 11 agreement must consist of “a written memorandum which is
complete within itself in every material detail, and which contains all of the essential elements of the
agreement.” Padilla v. LaFrance, 907 S.W.2d 454, 460 (Tex. 1995) (quoting Cohen v. McCutchin, 565
S.W.2d 230, 232 (Tex. 1978)); see Shamrock Psychiatric Clinic, P.A., 540 S.W.3d at 561. Nevertheless, the
terms of a Rule 11 agreement do not need to be contained within a single document. See Shamrock
Psychiatric Clinic, P.A., 540 S.W.3d at 561; Padilla, 907 S.W.2d at 455; Bandera Cnty. v. Hollingsworth, 419
S.W.3d 639, 645 (Tex. App.—San Antonio 2013, no pet.); Green v. Midland Mortg. Co., 342 S.W.3d 686,
692 (Tex. App.—Houston [14th Dist.] 2011, no pet.). A trial court has a ministerial duty to enforce a
valid Rule 11 agreement. See Shamrock Psychiatric Clinic, P.A., 540 S.W.3d at 560; Tex. Tax Sols., LLC v.
City of El Paso, 593 S.W.3d 903, 912 (Tex. App.—El Paso 2019, no pet.). See In re Philips, No. 13-21-
00312-CV, 2022 WL 354513, at *5–6 (Tex. App. Feb. 7, 2022).
Rule 11 of the Texas Rules of Civil Procedure provides that “no agreement between attorneys
or parties touching any suit pending will be enforced unless it be in writing, signed and filed with the
papers as part of the record, or unless it be made in open court and entered of record.” TEX. R. CIV.
P. 11. The Texas Supreme Court has analogized Rule 11's “in writing” requirement to the Statute of
Frauds, which is satisfied by “a written memorandum which is complete within itself in every material
detail, and which contains all of the essential elements of the agreement, so that the contract can be
ascertained from the writings without resorting to oral testimony.” Padilla v. LaFrance, 907 S.W.2d 454,
460 (Tex. 1995) (quoting Cohen v. McCutchin, 565 S.W.2d 230, 232 (Tex. 1978)). A settlement
agreement is not enforceable unless it satisfies the requirements of Rule 11. Id.
Rule 11 exists to ensure that agreements which peacefully and efficiently resolve disputes do
not themselves become a source of controversy or contention. See Padilla, 907 S.W.2d at 461
(describing the purpose of the rule as “to avoid disputes over the terms of oral settlement
agreements”).
In this case, the Rule 11 Agreement was made in open court and entered into the record. See
Exhibit A. There was no revocation or withdrawal of the Rule 11 Agreement. Neither party made
any oral or written statement which would affect the continuing validity of the Rule 11 Agreement.
Rather, Plaintiff has failed to comply with the terms of the Rule 11 Agreement dictated into the record
and counsel for Plaintiff failed to return an executed copy of the Rule 11 Agreement to be filed with
the Court as discussed in open court and entered into the record. See Exhibit A; Tex. R. Civ. P. 11;
See also In re Philips, No. 13-21-00312-CV, 2022 WL 354513, at *5–6 (Tex. App. Feb. 7, 2022).
The Texas Supreme Court has analogized Rule 11 to the Statute of Frauds, which requires “a
written memorandum which is complete within itself in every material detail, and which contains all
of the essential elements of the agreement, so that the contract can be ascertained from the writings
without resorting to oral testimony.” Padilla, 907 S.W.2d at 460 (quoting Cohen, 565 S.W.2d at 232).
“To allow the very existence of a contract to be negated by parol evidence would be to render the
Statute of Frauds a nullity. In fact, we would be encouraging frauds.” Givens v. Dougherty, 671 S.W.2d
877, 878 (Tex.1984) (holding that parties could not orally agree to rescind a contract subject to the
Statute of Frauds).
3
Electronically Filed
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Hidalgo County District Clerks
Reviewed By: Rachel Bueno
CONCLUSION
WHEREFORE, Defendant requests that this Court grant Defendant’s Motion to Enforce the
Parties' Rule 11 Agreement, and to such further relief to which they may be entitled.
Respectfully submitted,
RAMÓN WORTHINGTON
NICOLAS & CANTU, PLLC
1506 Lone Star Way, Suite 5
Edinburg, Texas 78539
Telephone: 956-294-4800
Facsimile: 956-928-9564
/s/ Dan K. Worthington
Dan K. Worthington
State Bar No. 00785282
dworthington@ramonworthington.com
Kristen L. Vela
State Bar No. 24107950
kvela@ramonworthington.com
Electronic Service to:
efile@ramonworthington.com
COWEN & GARZA, LLP
506 E. Dove Avenue
McAllen, Texas 78504
Telephone: 956.994.9170
Facsimile: 956.618.2324
/s/ Sarah Pierce Cowen
Sarah Pierce Cowen
State Bar No. 15997480
sarah@cowengarza.com
ATTORNEYS FOR DEFENDANT
ANTHONY JOHNSON
4
Electronically Filed
9/22/2023 2:21 PM
Hidalgo County District Clerks
Reviewed By: Rachel Bueno
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on September 22, 2023, a true and correct copy of the foregoing
document was served via e-File Texas.gov to the following:
Daniel A. Sanchez
Rio Grande Law Center
501 E. Tyler Ave.
Harlingen, Texas 78550
T: 956-425-5297
dan@sanchezlawyer.com
and
Stephen T. Leas
Leas Legal Group
P.O. Box 2257
McAllen, Texas 78502
T: 956-499-5327
stephen leas@msn.com
ATTORNEYS FOR PLAINTIFF
/s/Dan K. Worthington
Dan K. Worthington
5
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.
RW Firm on behalf of Daniel Worthington
Bar No. 785282
efile@ramonworthington.com
Envelope ID: 79852838
Filing Code Description: Motion (No Fee)
Filing Description: Def's Mtn to Enforce Rule 11 Agreement
Status as of 9/22/2023 2:36 PM CST
Associated Case Party: Patricia Nielsen, et al
Name BarNumber Email TimestampSubmitted Status
Woody Sanchez woody@sanchezlawyer.com 9/22/2023 2:21:29 PM SENT
Dora Perez dora@sanchezlawyer.com 9/22/2023 2:21:29 PM SENT
Daniel Sanchez dan@sanchezlaywer.com 9/22/2023 2:21:29 PM SENT
Stephen Leas stephen_leas@msn.com 9/22/2023 2:21:29 PM SENT
Associated Case Party: Anthony Johnson, et al
Name BarNumber Email TimestampSubmitted Status
Sarah PierceCowen sarah@cowengarza.com 9/22/2023 2:21:29 PM SENT
Dan K.Worthington dworthington@ramonworthington.com 9/22/2023 2:21:29 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Carolina Pavon carolina@cowengarza.com 9/22/2023 2:21:29 PM SENT
DAN KWORTHINGTON efile@ramonworthington.com 9/22/2023 2:21:29 PM SENT
Preview
Electronically Filed 9/22/2023 2:21 PM Hidalgo County District Clerks Reviewed By: Rachel Bueno CAUSE NO. C-2316-23-H PATRICIA NIELSEN, ET AL § IN THE DISTRICT COURT Plaintiffs, § § v. § 389TH JUDICIAL DISTRICT § ANTHONY JOHNSON, ET AL, § Defendants. § HIDALGO COUNTY, TEXAS DEFENDANT ANTHONY JOHNSON’S MOTION TO ENFORCE RULE 11 AGREEMENT INTRODUCTION On June 29th, 2023, this Court held a Hearing on Plaintiffs’ Application for Temporary Injunction (“the Hearing”) in connection with Cause No. C-2316-23-H; Patricia Nielsen, et al v. Anthony Johnson, et al; In the 389th Judicial District Court of Hidalgo County, Texas. A copy of the hearing transcript (“Hearing Transcript”) is attached as Exhibit A. Stephen Leas was present on behalf of the Plaintiff, Patricia Nielsen and Sarah Cowen and Dan Worthington were present on behalf of the Defendant, Anthony Johnson. The Parties reached an agreement at the hearing and dictated the terms of the agreement into the record. See Exhibit A, Hearing Transcript at page 4, ll 6-12. Despite the Parties reaching an agreement, Plaintiff refuses to fulfill her obligations under the agreement and it has become necessary to seek Court intervention. AGREEMENT At the Hearing, in open court, as evidenced by the Hearing Transcript, the Parties agreed to a Rule 11 Agreement with the following terms: A. Non-Destruction of Emails: MR. WORTHINGTON: Your Honor, the parties have agreed to meet in approximately two weeks to work through the issues that are alleged in the suit. The parties have agreed that neither party will destroy documents, e-mails, anything like that. We'll preserve all the evidence we have. The plaintiff -- THE COURT: What documents would those be? So I understand what you're talking about. See Hearing Transcript at page 5, ll 12-19. MS. COWEN: There's a d/b/a under which multiple companies operate, Your Honor. THE COURT: I want to make sure we understand -- you're going to put everything on the record. What businesses are you not destroying documents? MS. COWEN: All of the PEOs that operate under the d/b/a Corporate Solutions; and there's Electronically Filed 9/22/2023 2:21 PM Hidalgo County District Clerks Reviewed By: Rachel Bueno multiple of them. And I don't know that we're prepared to list all of them, but there's no disagreement between the parties as to which PEOs -- THE COURT: Anything that deals with Corporate Solutions? MR. LEAS: Yes, Your Honor. MR. WORTHINGTON: Yes, Your Honor. MS. COWEN: That's the big thing that's being unwound right now. THE COURT: Any business, anything that deals with Corporate Solutions? MR. WORTHINGTON: Yes, Your Honor. MR. LEAS: Yes, ma'am. THE COURT: Okay. See Hearing Transcript at page 6, ll 3-24. B. Email Accounts: MS. COWEN: Yes. They've also -- they've agreed -- the plaintiff has agreed to give the defendant access to his e-mail account that was cut off earlier. THE COURT: Which e-mail account? MR. WORTHINGTON: Your Honor, we have – there's five or six e-mail accounts. I don't have them here. We'll get them with the plaintiff, Your Honor. I apologize. THE COURT: Write them down so you can put it on the record. What e-mail accounts? MS. COWEN: Your Honor, as part of the – the unwinding that's already taken place, several employees that worked for both parties now have gone to work solely for Mr. Anthony Johnson. They all have e-mail addresses that are their initials at corpsolpeo.com -- C-O-R-P- S-O-L-P-E-O dot com. See Id, Hearing Transcript at page 7, ll 1-20. PLAINTIFF HAS FAILED TO COMPLY WITH THE AGREEMENT Following the Hearing, Defendant’s counsel sent Plaintiff’s counsel an executed copy of the Rule 11 Agreement that outlined the terms of the agreement and set out the identification of the email addresses in issue with specificity. See Exhibit B, Rule 11 Agreement. Plaintiff has refused to execute the memorialized agreement, has failed to comply with the agreement to meet in person to work through the issues involved in unwinding the business, and has failed to comply with the agreement to provide access to business email accounts set out in the record above. ARGUMENT & AUTHORITIES Texas Rule of Civil Procedure 11 provides that, “[u]nless otherwise provided in these rules, no agreement between attorneys or parties touching any suit pending will be enforced unless it be in writing, signed and filed with the papers as part of the record, or unless it be made in open court and entered of record.” Tex. R. Civ. P. 11. Agreements entered under Rule 11 “are contracts relating to litigation, and thus we construe them under the same rules as a contract.” Shamrock Psychiatric Clinic, P.A. v. Tex. Dep't of Health & Human Servs., 540 S.W.3d 553, 560 (Tex. 2018) (per curiam). “We do not give a Rule 11 agreement greater effect than the parties intended.” Id. at 560–61. Further, if the agreement can be given a certain or definite legal meaning or interpretation, it is not ambiguous, and 2 Electronically Filed 9/22/2023 2:21 PM Hidalgo County District Clerks Reviewed By: Rachel Bueno we construe it as a matter of law. Id. at 561 (citing Coker v. Coker, 650 S.W.2d 391, 393 (Tex. 1983)). See In re Philips, No. 13-21-00312-CV, 2022 WL 354513, at *5–6 (Tex. App. Feb. 7, 2022). To be effective, a Rule 11 agreement must consist of “a written memorandum which is complete within itself in every material detail, and which contains all of the essential elements of the agreement.” Padilla v. LaFrance, 907 S.W.2d 454, 460 (Tex. 1995) (quoting Cohen v. McCutchin, 565 S.W.2d 230, 232 (Tex. 1978)); see Shamrock Psychiatric Clinic, P.A., 540 S.W.3d at 561. Nevertheless, the terms of a Rule 11 agreement do not need to be contained within a single document. See Shamrock Psychiatric Clinic, P.A., 540 S.W.3d at 561; Padilla, 907 S.W.2d at 455; Bandera Cnty. v. Hollingsworth, 419 S.W.3d 639, 645 (Tex. App.—San Antonio 2013, no pet.); Green v. Midland Mortg. Co., 342 S.W.3d 686, 692 (Tex. App.—Houston [14th Dist.] 2011, no pet.). A trial court has a ministerial duty to enforce a valid Rule 11 agreement. See Shamrock Psychiatric Clinic, P.A., 540 S.W.3d at 560; Tex. Tax Sols., LLC v. City of El Paso, 593 S.W.3d 903, 912 (Tex. App.—El Paso 2019, no pet.). See In re Philips, No. 13-21- 00312-CV, 2022 WL 354513, at *5–6 (Tex. App. Feb. 7, 2022). Rule 11 of the Texas Rules of Civil Procedure provides that “no agreement between attorneys or parties touching any suit pending will be enforced unless it be in writing, signed and filed with the papers as part of the record, or unless it be made in open court and entered of record.” TEX. R. CIV. P. 11. The Texas Supreme Court has analogized Rule 11's “in writing” requirement to the Statute of Frauds, which is satisfied by “a written memorandum which is complete within itself in every material detail, and which contains all of the essential elements of the agreement, so that the contract can be ascertained from the writings without resorting to oral testimony.” Padilla v. LaFrance, 907 S.W.2d 454, 460 (Tex. 1995) (quoting Cohen v. McCutchin, 565 S.W.2d 230, 232 (Tex. 1978)). A settlement agreement is not enforceable unless it satisfies the requirements of Rule 11. Id. Rule 11 exists to ensure that agreements which peacefully and efficiently resolve disputes do not themselves become a source of controversy or contention. See Padilla, 907 S.W.2d at 461 (describing the purpose of the rule as “to avoid disputes over the terms of oral settlement agreements”). In this case, the Rule 11 Agreement was made in open court and entered into the record. See Exhibit A. There was no revocation or withdrawal of the Rule 11 Agreement. Neither party made any oral or written statement which would affect the continuing validity of the Rule 11 Agreement. Rather, Plaintiff has failed to comply with the terms of the Rule 11 Agreement dictated into the record and counsel for Plaintiff failed to return an executed copy of the Rule 11 Agreement to be filed with the Court as discussed in open court and entered into the record. See Exhibit A; Tex. R. Civ. P. 11; See also In re Philips, No. 13-21-00312-CV, 2022 WL 354513, at *5–6 (Tex. App. Feb. 7, 2022). The Texas Supreme Court has analogized Rule 11 to the Statute of Frauds, which requires “a written memorandum which is complete within itself in every material detail, and which contains all of the essential elements of the agreement, so that the contract can be ascertained from the writings without resorting to oral testimony.” Padilla, 907 S.W.2d at 460 (quoting Cohen, 565 S.W.2d at 232). “To allow the very existence of a contract to be negated by parol evidence would be to render the Statute of Frauds a nullity. In fact, we would be encouraging frauds.” Givens v. Dougherty, 671 S.W.2d 877, 878 (Tex.1984) (holding that parties could not orally agree to rescind a contract subject to the Statute of Frauds). 3 Electronically Filed 9/22/2023 2:21 PM Hidalgo County District Clerks Reviewed By: Rachel Bueno CONCLUSION WHEREFORE, Defendant requests that this Court grant Defendant’s Motion to Enforce the Parties' Rule 11 Agreement, and to such further relief to which they may be entitled. Respectfully submitted, RAMÓN WORTHINGTON NICOLAS & CANTU, PLLC 1506 Lone Star Way, Suite 5 Edinburg, Texas 78539 Telephone: 956-294-4800 Facsimile: 956-928-9564 /s/ Dan K. Worthington Dan K. Worthington State Bar No. 00785282 dworthington@ramonworthington.com Kristen L. Vela State Bar No. 24107950 kvela@ramonworthington.com Electronic Service to: efile@ramonworthington.com COWEN & GARZA, LLP 506 E. Dove Avenue McAllen, Texas 78504 Telephone: 956.994.9170 Facsimile: 956.618.2324 /s/ Sarah Pierce Cowen Sarah Pierce Cowen State Bar No. 15997480 sarah@cowengarza.com ATTORNEYS FOR DEFENDANT ANTHONY JOHNSON 4 Electronically Filed 9/22/2023 2:21 PM Hidalgo County District Clerks Reviewed By: Rachel Bueno CERTIFICATE OF SERVICE I HEREBY CERTIFY that on September 22, 2023, a true and correct copy of the foregoing document was served via e-File Texas.gov to the following: Daniel A. Sanchez Rio Grande Law Center 501 E. Tyler Ave. Harlingen, Texas 78550 T: 956-425-5297 dan@sanchezlawyer.com and Stephen T. Leas Leas Legal Group P.O. Box 2257 McAllen, Texas 78502 T: 956-499-5327 stephen leas@msn.com ATTORNEYS FOR PLAINTIFF /s/Dan K. Worthington Dan K. Worthington 5 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. RW Firm on behalf of Daniel Worthington Bar No. 785282 efile@ramonworthington.com Envelope ID: 79852838 Filing Code Description: Motion (No Fee) Filing Description: Def's Mtn to Enforce Rule 11 Agreement Status as of 9/22/2023 2:36 PM CST Associated Case Party: Patricia Nielsen, et al Name BarNumber Email TimestampSubmitted Status Woody Sanchez woody@sanchezlawyer.com 9/22/2023 2:21:29 PM SENT Dora Perez dora@sanchezlawyer.com 9/22/2023 2:21:29 PM SENT Daniel Sanchez dan@sanchezlaywer.com 9/22/2023 2:21:29 PM SENT Stephen Leas stephen_leas@msn.com 9/22/2023 2:21:29 PM SENT Associated Case Party: Anthony Johnson, et al Name BarNumber Email TimestampSubmitted Status Sarah PierceCowen sarah@cowengarza.com 9/22/2023 2:21:29 PM SENT Dan K.Worthington dworthington@ramonworthington.com 9/22/2023 2:21:29 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Carolina Pavon carolina@cowengarza.com 9/22/2023 2:21:29 PM SENT DAN KWORTHINGTON efile@ramonworthington.com 9/22/2023 2:21:29 PM SENT