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FILED
10/7/2021 4:02 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Debra Clark DEPUTY
No. DC-20-12534
RENATA PETRYLIENE AND BIG § IN THE DISTRICT COURT
RIVER NV,
§§§§§§§§§§§§§§§§§§§§§§§§§§§
PlaintiffslCounter—Defendants,
V.
BRADFORD PHILLIPS, INDIVIDUALLY
ICC SURRWOOD CORP.,
CHEYENNE ASSET MANAGEMENT,
INC. DONALD W. PHILLIPS, MICKEY
NED PHILLIPS, NICKEY TED PHILLIPS 191 st JUDICIAL DISTRICT
LONGFELLOW INVESTORS I, LLC,
LONGFELLOW INVESTORS II, LLC,
LONGFELLOW INVESTORS III, LLC,
LONGFELLOW INVESTORS IV, LLC,
LONGFELLOW INVESTORS V, LLC,
LOUIS J. CORNA, KENNETH K.
FOGG, AND BENNETT, WESTON,
LAJONE & TURNER, P.C.,
Defendants/Counter-Plaintiffs
v.
DALLAS HRS DEVELOPMENT, INC.
AND JRG INVESTMENT CO. INC.
lntervenors DALLAS COUNTY, TEXAS
DEFENDANTS’ MOTION TO DEEM ANSWERS TO DEFENDANTS’
REQUEST FOR ADMISSIONS TO PLAINTIFF RENATA PETRYLIENE
REGARDING PAYMENTS ADMITTED OR ALTERNATIVELY TO COMPEL
PLAINTIFF TO ANSWER
Defendants Nickey Ted Phillips, Mickey Ned Phillips, Donald W. Phillips,
Bradford Phillips, Louis J. Corna and Bennett, Weston, LaJone & Turner, P.C.
(collectively “Defendants”) move to deem answers to Defendants’ Request for
DEFENDANTS’ MOTION TO COMPEL PAGE 1 0F 6
Admissions to Plaintiff Renata Petryliene (“Plaintiff”) Regarding Payments‘ (the
“ROAs”) Numbers 1-6, 9-35 admitted or alternatively Defendants move to compel
Plaintiff to answer same and for sanctions. ln support, Defendants show the Court
as follows:
I. PLAINTIFF’S ANSWERS ARE DEFICIENT AND SPECIOUS.
Tex. R. Civ. P. 198.2 (b) governs the content of Plaintiff’s Response to the
ROAs. It states, in relevant part, as follows:
Unless the responding party states an objection or asserts a privilege,
the responding party must specifically admit or deny the request or
explain in detail the reasons that the responding party cannot admit
or deny the request. A response must fairly meet the substance of the
request. The responding party may qualify an answer, or deny a
request in part, only when good faith requires. Lack of
information or knowledge is not a proper response unless the
responding party states that a reasonable inquiry was made but
that the information known or easily obtainable is insufficient to
enable the responding party to admit or deny.
Tex. R. Civ. P. 198.2 (bold and italics added). The Plaintiff’s responses to ROAs
Numbers 1-6, 9-35 are deficient and specious.
The responses to each request in the ROAs (other than Requests 7 and 8)
state that “Plaintiffs lack sufficient information to admit or deny this request” and
then either state that they are “investigating potential alteration of the document,
or forgery of the signatures...,” or that “they are investigating transfers made by
Defendants, or on Defendants’ behalf, through entities or accounts purportedly
1
A true and correct copy of which is attached as Exhibit 5 to the Declaration of Mitchell Madden which
will be filed upon entry of an order from the Court on a Motion for Leave to File.
DEFENDANTS’ MOTION TO COMPEL PAGE 2 0F 6
owned by, controlled by, or for held for the benefit of Petryliene.” However, these
responses are not made in good faith nor do they comply with Rule 198.2.
Request Numbers 1-6, 9-35 The requests do not seek information which is
outside Ms. Petryliene’s knowledge (or which is easily obtainable by her). By way
of non-limiting example, it is disingenuous for Plaintiff to claim that she has to
investigate alteration or forgery of the notes. Ms. Petryliene knows whether she
signed the notes attached to the ROAs or whether she did not. And, Defendants
are entitled to an unqualified admission or denial in that regard. The same is true
with respect to the requests regarding payments. Ms. Petryliene, either through
her accounts or one of her entities—knows whether or not she received the
payments that are the subject of those requests. If she did, she admits—if not,
she denies. It’s as simple as that—or, to the extent she doesn’t immediately recall,
she looks at the bank statements or other documentation under her possession,
custody and control, and finds out. Indeed, that’s the purpose of the 30-day gap
between service of discovery and the requirement to answer. Here, not only did
Plaintiff have 30-days to respond, she had an additional 15-day agreed upon
extension as well. The Plaintiff’s purported lack of information or knowledge is not
a proper response unless she states she made a reasonable inquiry that the
information known or easily obtainable was insufficient to enable her to admit or
deny the request. Here, no doubt information either known or easily obtainable by
the Plaintiff upon reasonable inquiry would have allowed her to answer the
questions. Instead, she chose to evade discovery.
DEFENDANTS’ MOTION TO COMPEL PAGE 3 OF 6
The Plaintiff’s answers are insufficient, evasive and incomplete. Under
these circumstances, the Plaintiff’s answers to Request Numbers 1-6, 9-35 of the
ROAs should be treated as a failure to answer and order that these matters be
admitted. See Tex. R. Civ. P. 215.4. Alternatively, the Court should order that an
amended answer to each of these requests be immediately served.
Further, prior to filing this Motion, the Defendants’ attorney corresponded
with counsel for the Plaintiffs regarding the issues presented in this Motion? The
Plaintiffs’ attorneys failed to respond. Accordingly, pursuant to Tex. R. Civ. P.
215.1(d) (which is applicable to failure to comply with Rule 198 through Rule
215.4), the Defendants herein seek their reasonable expenses, including
attorneys’ fees, caused by Plaintiff’s discovery abuses in connection with the
ROAs. Defendants’ counsel anticipates offering evidence in support of fees at the
hearing on this Motion.
VII. CONCLUSION AND PRAYER
For the foregoing reasons, Defendants respectfully request that the Court
treat Plaintiff’s answers to Request Numbers 1-6, 9-35 of the ROAs as a failure to
answer and order that these matters are admitted. See Tex. R. Civ. P. 215.4.
Alternatively, Defendants askthat the Court orderthat an amended answer to each
of these requests be immediately served. Further, Defendants request their
2
See Exhibits 6, 7 and 8 attached to the Declaration of Mitchell Madden.
DEFENDANTS’ MOTION TO COMPEL PAGE 4 0F 6
reasonable expenses, including attorneys’ fees, caused by Plaintiffs discovery
abuses in connection with the ROAs.
WHEREFORE PREMISES CONSIDERED, Defendants Nickey Ted Phillips,
Mickey Ned Phillips, Donald W. Phillips, Louis J. Corna and Bennett, Weston,
LaJone & Turner, P.C. respectfully request that the Court enter an Order treating
Plaintiff’s answers to Request Numbers 1-6, 9-35 of the ROAs as a failure to
answer and ordering that these matters are admitted. Alternatively, Defendants
ask that the Court order that an amended answer to each of these requests be
immediately served by Plaintiff. Further, Defendants request their reasonable
expenses, including attorneys’ fees, caused by Plaintiff’s discovery abuses in
connection with the ROAs. Defendants also request such other relief to which they
have shown themselves entitled.
Respectfully submitted,
By: /s/ Mitchell Madden
Mitchell Madden
State Bar No. 12789350
Email:mmadden@himmleqal.com;
skinnev@himmleqal.com
Melissa Johnson
State Bar No. 19142900
Email: Melissa@himmleqal.com
Dennis Holmgren
State Bar No. 24036799
Email: dennis@hjmmlegal.com
HOLMGREN JOHNSON:
MITCHELL MADDEN, LLP
12801 North Central Expressway
Suite 140
Dallas, Texas 75243
DEFENDANTS’ MOTION TO COMPEL PAGE 5 OF 6
Telephone: 972-484-7780
Facsimile: 972-484-7743
ATTORNEYS FOR PLAINTIFFS
_ERTIFICATE OF CONFERENCE
|
hereby certify that conferred via letter on September 2, 2021 with counsel
|
for Plaintiffs regarding the issues raised in this motion, and asked for responses to
the discovery by the close of business on September 10, 2021, asked for any
reasons or contentions as to why Plaintiffs should not comply for purposes of
conference but received no response. Therefore, this Motion is submitted to the
Court for determination.
/s/ Mitchell Madden
Mitchell Madden
_ERTIFICATE OF S_ERVIC§
lhereby certify that a true and correct copy of the foregoing was served on
counsel of record according to the Texas Rules of Civil Procedure on October 7,
2021.
/s/ Mitchell Madden
Mitchell Madden
DEFENDANTS’ MOTION TO COMPEL PAGE 6 OF 6
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.
Tania Flores on behalf of Mitchell Madden
Bar No. 12789350
tflores@hjmmlegal.com
Envelope ID: 57990737
Status as of 10/8/2021 9:04 AM CST
Associated Case Party: RENATA PETRYLIENE
Name BarNumber Email TimestampSubmitted Status
Bradley Ryynanen 24082520 brad@bdrlega|.com 10/7/2021 4:02:58 PM SENT
Ralph Ritch Roberts 24041794 roberts@rrobertslaw.com 10/7/2021 4:02:58 PM SENT
Associated Case Party: ICC SURFWOOD CORP
Name BarNumber Email TimestampSubmitted Status
Jeffrey MTilIotson jtillotson@tillotsonlaw.com 10/7/2021 4:02:58 PM SENT
Jonathan RPatton jpatton@tillotson|aw.com 10/7/2021 4:02:58 PM SENT
Associated Case Party: CHEYENNE ASSET MANAGEMENT INC
Name BarNumber Email TimestampSubmitted Status
H. Grady Chandler grady@hgchandlerlaw.com 10/7/2021 4:02:58 PM SENT
Associated Case Party: KENNETHKFOGG
Name BarNumber Email TimestampSubmitted Status
Daniel D.Tostrud dtostrud@cobbmartinez.com 10/7/2021 4:02:58 PM SENT
Virginia E.Cox vcox@cobbmartinez.com 10/7/2021 4:02:58 PM SENT
Dolly Whitaker dwhitaker@cobbmartinez.com 10/7/2021 4:02:58 PM SENT
Karyn Elder kelder@cobbmartinez.com 10/7/2021 4:02:58 PM SENT
Case Contacts
Name
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.
Tania Flores on behalf of Mitchell Madden
Bar No. 12789350
tflores@hjmmlegal.com
Envelope ID: 57990737
Status as of 10/8/2021 9:04 AM CST
Case Contacts
Mitchell Madden mmadden@hjmmlegal.com 10/7/2021 4:02:58 PM SENT
Shawnte Kinney skinney@hjmmlegal.com 10/7/2021 4:02:58 PM SENT
Melissa Johnson Melissa@hjmmlegal.com 10/7/2021 4:02:58 PM SENT
Dennis Holmgren Dennis@hjmmlegal.com 10/7/2021 4:02:58 PM SENT
Jordan L. Vimont jvimont@rctlegal.com 10/7/2021 4:02:58 PM SENT
Joseph Alrrobali airrobali@tillotsonlaw.com 10/7/2021 4:02:58 PM SENT
Veronica Zavala veronica@hgchandlerlaw.com 10/7/2021 4:02:58 PM SENT
Rachel A.Buchhorn rbuchhorn@reidcollins.com 10/7/2021 4:02:58 PM SENT
Lisa tsai ltsai@reidcollins.com 10/7/2021 4:02:58 PM SENT
Misty Gasiorowski mgasiorowski@wkpz.com 10/7/2021 4:02:58 PM SENT
Susie Wade swade@tillotsonlaw.com 10/7/2021 4:02:58 PM SENT
Ashli Durke adurke@rctlegal.com 10/7/2021 4:02:58 PM SENT
Kira Lytle klytle@tillotsonlaw.com 10/7/2021 4:02:58 PM SENT
Enrique Ramirez eramirez@tillotsonlaw.com 10/7/2021 4:02:58 PM SENT
Benjamin LNabors bnabors@tillotsonlaw.com 10/7/2021 4:02:58 PM SENT
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FILED 10/7/2021 4:02 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Debra Clark DEPUTY No. DC-20-12534 RENATA PETRYLIENE AND BIG § IN THE DISTRICT COURT RIVER NV, §§§§§§§§§§§§§§§§§§§§§§§§§§§ PlaintiffslCounter—Defendants, V. BRADFORD PHILLIPS, INDIVIDUALLY ICC SURRWOOD CORP., CHEYENNE ASSET MANAGEMENT, INC. DONALD W. PHILLIPS, MICKEY NED PHILLIPS, NICKEY TED PHILLIPS 191 st JUDICIAL DISTRICT LONGFELLOW INVESTORS I, LLC, LONGFELLOW INVESTORS II, LLC, LONGFELLOW INVESTORS III, LLC, LONGFELLOW INVESTORS IV, LLC, LONGFELLOW INVESTORS V, LLC, LOUIS J. CORNA, KENNETH K. FOGG, AND BENNETT, WESTON, LAJONE & TURNER, P.C., Defendants/Counter-Plaintiffs v. DALLAS HRS DEVELOPMENT, INC. AND JRG INVESTMENT CO. INC. lntervenors DALLAS COUNTY, TEXAS DEFENDANTS’ MOTION TO DEEM ANSWERS TO DEFENDANTS’ REQUEST FOR ADMISSIONS TO PLAINTIFF RENATA PETRYLIENE REGARDING PAYMENTS ADMITTED OR ALTERNATIVELY TO COMPEL PLAINTIFF TO ANSWER Defendants Nickey Ted Phillips, Mickey Ned Phillips, Donald W. Phillips, Bradford Phillips, Louis J. Corna and Bennett, Weston, LaJone & Turner, P.C. (collectively “Defendants”) move to deem answers to Defendants’ Request for DEFENDANTS’ MOTION TO COMPEL PAGE 1 0F 6 Admissions to Plaintiff Renata Petryliene (“Plaintiff”) Regarding Payments‘ (the “ROAs”) Numbers 1-6, 9-35 admitted or alternatively Defendants move to compel Plaintiff to answer same and for sanctions. ln support, Defendants show the Court as follows: I. PLAINTIFF’S ANSWERS ARE DEFICIENT AND SPECIOUS. Tex. R. Civ. P. 198.2 (b) governs the content of Plaintiff’s Response to the ROAs. It states, in relevant part, as follows: Unless the responding party states an objection or asserts a privilege, the responding party must specifically admit or deny the request or explain in detail the reasons that the responding party cannot admit or deny the request. A response must fairly meet the substance of the request. The responding party may qualify an answer, or deny a request in part, only when good faith requires. Lack of information or knowledge is not a proper response unless the responding party states that a reasonable inquiry was made but that the information known or easily obtainable is insufficient to enable the responding party to admit or deny. Tex. R. Civ. P. 198.2 (bold and italics added). The Plaintiff’s responses to ROAs Numbers 1-6, 9-35 are deficient and specious. The responses to each request in the ROAs (other than Requests 7 and 8) state that “Plaintiffs lack sufficient information to admit or deny this request” and then either state that they are “investigating potential alteration of the document, or forgery of the signatures...,” or that “they are investigating transfers made by Defendants, or on Defendants’ behalf, through entities or accounts purportedly 1 A true and correct copy of which is attached as Exhibit 5 to the Declaration of Mitchell Madden which will be filed upon entry of an order from the Court on a Motion for Leave to File. DEFENDANTS’ MOTION TO COMPEL PAGE 2 0F 6 owned by, controlled by, or for held for the benefit of Petryliene.” However, these responses are not made in good faith nor do they comply with Rule 198.2. Request Numbers 1-6, 9-35 The requests do not seek information which is outside Ms. Petryliene’s knowledge (or which is easily obtainable by her). By way of non-limiting example, it is disingenuous for Plaintiff to claim that she has to investigate alteration or forgery of the notes. Ms. Petryliene knows whether she signed the notes attached to the ROAs or whether she did not. And, Defendants are entitled to an unqualified admission or denial in that regard. The same is true with respect to the requests regarding payments. Ms. Petryliene, either through her accounts or one of her entities—knows whether or not she received the payments that are the subject of those requests. If she did, she admits—if not, she denies. It’s as simple as that—or, to the extent she doesn’t immediately recall, she looks at the bank statements or other documentation under her possession, custody and control, and finds out. Indeed, that’s the purpose of the 30-day gap between service of discovery and the requirement to answer. Here, not only did Plaintiff have 30-days to respond, she had an additional 15-day agreed upon extension as well. The Plaintiff’s purported lack of information or knowledge is not a proper response unless she states she made a reasonable inquiry that the information known or easily obtainable was insufficient to enable her to admit or deny the request. Here, no doubt information either known or easily obtainable by the Plaintiff upon reasonable inquiry would have allowed her to answer the questions. Instead, she chose to evade discovery. DEFENDANTS’ MOTION TO COMPEL PAGE 3 OF 6 The Plaintiff’s answers are insufficient, evasive and incomplete. Under these circumstances, the Plaintiff’s answers to Request Numbers 1-6, 9-35 of the ROAs should be treated as a failure to answer and order that these matters be admitted. See Tex. R. Civ. P. 215.4. Alternatively, the Court should order that an amended answer to each of these requests be immediately served. Further, prior to filing this Motion, the Defendants’ attorney corresponded with counsel for the Plaintiffs regarding the issues presented in this Motion? The Plaintiffs’ attorneys failed to respond. Accordingly, pursuant to Tex. R. Civ. P. 215.1(d) (which is applicable to failure to comply with Rule 198 through Rule 215.4), the Defendants herein seek their reasonable expenses, including attorneys’ fees, caused by Plaintiff’s discovery abuses in connection with the ROAs. Defendants’ counsel anticipates offering evidence in support of fees at the hearing on this Motion. VII. CONCLUSION AND PRAYER For the foregoing reasons, Defendants respectfully request that the Court treat Plaintiff’s answers to Request Numbers 1-6, 9-35 of the ROAs as a failure to answer and order that these matters are admitted. See Tex. R. Civ. P. 215.4. Alternatively, Defendants askthat the Court orderthat an amended answer to each of these requests be immediately served. Further, Defendants request their 2 See Exhibits 6, 7 and 8 attached to the Declaration of Mitchell Madden. DEFENDANTS’ MOTION TO COMPEL PAGE 4 0F 6 reasonable expenses, including attorneys’ fees, caused by Plaintiffs discovery abuses in connection with the ROAs. WHEREFORE PREMISES CONSIDERED, Defendants Nickey Ted Phillips, Mickey Ned Phillips, Donald W. Phillips, Louis J. Corna and Bennett, Weston, LaJone & Turner, P.C. respectfully request that the Court enter an Order treating Plaintiff’s answers to Request Numbers 1-6, 9-35 of the ROAs as a failure to answer and ordering that these matters are admitted. Alternatively, Defendants ask that the Court order that an amended answer to each of these requests be immediately served by Plaintiff. Further, Defendants request their reasonable expenses, including attorneys’ fees, caused by Plaintiff’s discovery abuses in connection with the ROAs. Defendants also request such other relief to which they have shown themselves entitled. Respectfully submitted, By: /s/ Mitchell Madden Mitchell Madden State Bar No. 12789350 Email:mmadden@himmleqal.com; skinnev@himmleqal.com Melissa Johnson State Bar No. 19142900 Email: Melissa@himmleqal.com Dennis Holmgren State Bar No. 24036799 Email: dennis@hjmmlegal.com HOLMGREN JOHNSON: MITCHELL MADDEN, LLP 12801 North Central Expressway Suite 140 Dallas, Texas 75243 DEFENDANTS’ MOTION TO COMPEL PAGE 5 OF 6 Telephone: 972-484-7780 Facsimile: 972-484-7743 ATTORNEYS FOR PLAINTIFFS _ERTIFICATE OF CONFERENCE | hereby certify that conferred via letter on September 2, 2021 with counsel | for Plaintiffs regarding the issues raised in this motion, and asked for responses to the discovery by the close of business on September 10, 2021, asked for any reasons or contentions as to why Plaintiffs should not comply for purposes of conference but received no response. Therefore, this Motion is submitted to the Court for determination. /s/ Mitchell Madden Mitchell Madden _ERTIFICATE OF S_ERVIC§ lhereby certify that a true and correct copy of the foregoing was served on counsel of record according to the Texas Rules of Civil Procedure on October 7, 2021. /s/ Mitchell Madden Mitchell Madden DEFENDANTS’ MOTION TO COMPEL PAGE 6 OF 6 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. Tania Flores on behalf of Mitchell Madden Bar No. 12789350 tflores@hjmmlegal.com Envelope ID: 57990737 Status as of 10/8/2021 9:04 AM CST Associated Case Party: RENATA PETRYLIENE Name BarNumber Email TimestampSubmitted Status Bradley Ryynanen 24082520 brad@bdrlega|.com 10/7/2021 4:02:58 PM SENT Ralph Ritch Roberts 24041794 roberts@rrobertslaw.com 10/7/2021 4:02:58 PM SENT Associated Case Party: ICC SURFWOOD CORP Name BarNumber Email TimestampSubmitted Status Jeffrey MTilIotson jtillotson@tillotsonlaw.com 10/7/2021 4:02:58 PM SENT Jonathan RPatton jpatton@tillotson|aw.com 10/7/2021 4:02:58 PM SENT Associated Case Party: CHEYENNE ASSET MANAGEMENT INC Name BarNumber Email TimestampSubmitted Status H. Grady Chandler grady@hgchandlerlaw.com 10/7/2021 4:02:58 PM SENT Associated Case Party: KENNETHKFOGG Name BarNumber Email TimestampSubmitted Status Daniel D.Tostrud dtostrud@cobbmartinez.com 10/7/2021 4:02:58 PM SENT Virginia E.Cox vcox@cobbmartinez.com 10/7/2021 4:02:58 PM SENT Dolly Whitaker dwhitaker@cobbmartinez.com 10/7/2021 4:02:58 PM SENT Karyn Elder kelder@cobbmartinez.com 10/7/2021 4:02:58 PM SENT Case Contacts Name 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. Tania Flores on behalf of Mitchell Madden Bar No. 12789350 tflores@hjmmlegal.com Envelope ID: 57990737 Status as of 10/8/2021 9:04 AM CST Case Contacts Mitchell Madden mmadden@hjmmlegal.com 10/7/2021 4:02:58 PM SENT Shawnte Kinney skinney@hjmmlegal.com 10/7/2021 4:02:58 PM SENT Melissa Johnson Melissa@hjmmlegal.com 10/7/2021 4:02:58 PM SENT Dennis Holmgren Dennis@hjmmlegal.com 10/7/2021 4:02:58 PM SENT Jordan L. Vimont jvimont@rctlegal.com 10/7/2021 4:02:58 PM SENT Joseph Alrrobali airrobali@tillotsonlaw.com 10/7/2021 4:02:58 PM SENT Veronica Zavala veronica@hgchandlerlaw.com 10/7/2021 4:02:58 PM SENT Rachel A.Buchhorn rbuchhorn@reidcollins.com 10/7/2021 4:02:58 PM SENT Lisa tsai ltsai@reidcollins.com 10/7/2021 4:02:58 PM SENT Misty Gasiorowski mgasiorowski@wkpz.com 10/7/2021 4:02:58 PM SENT Susie Wade swade@tillotsonlaw.com 10/7/2021 4:02:58 PM SENT Ashli Durke adurke@rctlegal.com 10/7/2021 4:02:58 PM SENT Kira Lytle klytle@tillotsonlaw.com 10/7/2021 4:02:58 PM SENT Enrique Ramirez eramirez@tillotsonlaw.com 10/7/2021 4:02:58 PM SENT Benjamin LNabors bnabors@tillotsonlaw.com 10/7/2021 4:02:58 PM SENT