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  • STROM AVIATION, INC.  vs.  ROBINSON AIRCRAFT INTERIORS, INC., et alOTHER (CIVIL) document preview
  • STROM AVIATION, INC.  vs.  ROBINSON AIRCRAFT INTERIORS, INC., et alOTHER (CIVIL) document preview
  • STROM AVIATION, INC.  vs.  ROBINSON AIRCRAFT INTERIORS, INC., et alOTHER (CIVIL) document preview
  • STROM AVIATION, INC.  vs.  ROBINSON AIRCRAFT INTERIORS, INC., et alOTHER (CIVIL) document preview
  • STROM AVIATION, INC.  vs.  ROBINSON AIRCRAFT INTERIORS, INC., et alOTHER (CIVIL) document preview
  • STROM AVIATION, INC.  vs.  ROBINSON AIRCRAFT INTERIORS, INC., et alOTHER (CIVIL) document preview
  • STROM AVIATION, INC.  vs.  ROBINSON AIRCRAFT INTERIORS, INC., et alOTHER (CIVIL) document preview
  • STROM AVIATION, INC.  vs.  ROBINSON AIRCRAFT INTERIORS, INC., et alOTHER (CIVIL) document preview
						
                                

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FH_ED DALLAS COUNTY 7/22/2019 5:44 PM FELICIA PITRE DISTRICT CLERK Martin Reyes CAUSE NO. DC-16-11118 STROM AVIATION, INC. IN THE DISTRICT COURT OF Plaintiff, V. ROBINSON AIRCRAFT INTERIORS, INC.; JEFFREY WAYNE ROBINSON; JOE WAYNE ROBINSON; AND AVIATION CONSULTING EXPERTS, INC.; J&J ROBINSON VENTURES, DALLAS COUNTY, TEXAS LLC; JOSEPH W. PARK AND STACEY ROBINSON Defendants, WWWWWWWWWWWWWWWWWWWWWWWWWWWW V. ROBINSON AIRCRAFT INTERIORS, INC. Third-Party Plaintiff, V. DANIEL G. WROLSON Third-Party Defendant. 95TH JUDICIAL DISTRICT THIRD SUPPLEMENTAL EXHIBITS T0: DEFENDANTS’ RESPONSE T0 PLAINTIFF’S MOTION T0 VACATE ORDERS 0F THE COURT; DEFENDANTS’ RESPONSE T0 MOTION T0 CONDUCT PRE—TRIAL CONFERENCE; DEFENDANTS’ RESPONSE TO PLAINTIFF’S MOTION TO ADMIT ATTORNEY PRO HAC VICE AND DESIGNATION OF ATTORNEY IN CHARGE; AND DEFENDANTS’ MOTION TO ENFORCE SETTLEMENT AGREEMENT Third Supplemental Exhibits to Defendants’ Response and Motion Enforce Settlement Agreement Page 1 of 3 437078 Robinson Aircraft Interiors, Inc. (“KAI”), Jeffrey Wayne Robinson, Joe Wayne Robinson, J&J Robinson Ventures, LLC (“J&J”), and Aviation Consulting Experts, Inc. (“ACES”) (collectively the “Defendants”) hereby file the attached Exhibit I and Exhibit J as Supplemental Exhibits t0 Response t0 Plaintiff’s Motion t0 Vacate Orders 0f the Court; Response t0 Plaintiff” s Motion t0 Conduct Pre-trial Conference; Response t0 Plaintiff’s Motion t0 Admit Attorney Pro Hac Vice and Designation 0f Attorney in Charge; and Defendants’ Motion t0 Enforce Settlement Agreement. Respectfully submitted, By: /s/Jerr'y C. Alexander Jerry C. Alexander Texas State Bar N0. 00993500 alexanderj @passmanj 0nes.com John G. Browning Texas State Bar N0. 03223050 browningj @passmanjones.com Christopher A. Robison Texas State Bar N0. 24035720 robisonc@passmanj0nes.com PASSMAN & JONES A Professional Corporation 1201 Elm 2500 Street, Suite Dallas, Texas 75270-2599 (214) 742-2121 Telephone (214) 748-7949 Facsimile ATTORNEYS FOR DEFENDANTS, ROBINSON AIRCRAFT INTERIORS, INC., JEFFREY WAYNE ROBINSON, JOE WAYNE ROBINSON, AVIATION CONSULTING EXPERTS, INC, J&J ROBINSON VENTURES, LLC, and STACEY ROBINSON Third Supplemental Exhibits to Defendants’ Response and Motion Enforce Settlement Agreement Page 2 of 3 437078 CERTIFICATE OF SERVICE This will certify that a true and correct copy 0f the above and foregoing document has been served, Via electronic filing, 0n all counsel 0f record 0n this the 22nd day 0f July, 2019. /s/Jerry C. Alexander Jerry C. Alexander Third Supplemental Exhibits to Defendants’ Response and Motion Enforce Settlement Agreement Page 3 of 3 437078 EXHIBIT I I CAUSE NO. CAUSE NO. DC-16-11118 DC-16-11118 STROM AVIATION, STROM AVIATION, INC. INC. §§ THE DISTRICT IN THE IN COURT DISTRICT COURT §§ Plaintiff, Plaintiff, §§ §§ v.V. §§ §§ ROBINSON AIRCRAFTINTERIORS, ROBINSON AIRCRAFT INTERIORS, §§ INC., et al. INC., et al. §§ DALLAS COUNTY, DALLAS TEXAS COUNTY, TEXAS §§ Defendants, Defendants, §§ §§ v. V. §§ §§ DANIEL G. DANIEL WROLSON G. WROLSON §§ §§ Third-Party Third-Party Defendant. Defendant. §§ 95THJUDICIAL 95TH DISTRICT JUDICIAL DISTRICT OF LUPE AFFIDAVIT OF AFFIDAVIT LOPEZ LUPE LOPEZ “Myname "My LUPELOPEZ. nameisisLUPE amover LOPEZ. IIam overthe the age ageof oftwenty-one twenty-one(21 ), and (21), amfully andam compe-tent fullycompetent and capable and capable in in all all respects respects to make this to make this affidavit. affidavit. All All of ofthe the facts facts contained contained within within this this affidavit affidavit are are true and correct true and and are correct and based upon are based mypersonal upon my knowledge. personal knowledge. 1.1. am the II am the Facilities Facilities Coordinator and Court Coordinator and Runner for Court Runner for the the law firm of law firm Passman and ofPassman and Jones, Jones, aa Professional Professional Corporation. Corporation. 2.2. OnJuly15, On JulylS, 2019, 2019, II attempted attempted to todeliver deliveraa$150,000.00 checkto $ 150,000.00check to Robert RobertMaris, Maris, Esq., Esq., Glast, Glast, Phillips &Murray, Phillips & Murray, P.C.; P.C.; 14801 Quorum Drive, 14801 Quorum Drive, Suite Suite 500; 500; Dallas, TX 75254. Dallas, TX 75254. 3.3. The check The was from check was from Robinson Robinson Aircraft Aircraft Interiors, Interiors, Inc., and itit was Inc., and made payable was made payable to to Strom Aviation, Strom Aviation, Inc. Inc. 4.4. After After initially initially speaking speaking with with Mr. Maris’s legal Mr. Maris's legal assistant, spoke with assistant, II spoke with Mr. Mr. Maris Maris and attempted and attempted to to deliver deliver the the check. When II attempted check. When attempted to to deliver deliver the check to the check Mr. Maris, to Mr. Maris, he he stated stated that that he would not he would not accept accept the the check. check. FURTHER AFFIANT FURTHER AFFIANT SA SAYETI—I NOT. YETH NOT. Affidavit Affidavit of Lupe Lopez ofLupe Lopez Page 11 Page 437053 437053 ' ’ U66 Lop é/ ,Affiant BEFORE ME, the the undersigned authority, authority, on this this day personally personally appeared Lupe Lopez, known toto me to to be the the person person whose name isis subscribed subscribed toto the the above and foregoing foregoing instrument, instrument, and acknowledged to to me that that he/she executed the the same for for the the purposes and considerations therein therein expressed. GIVEN UNDER MY HAND AND SEAL OF this? ?.11~ 0F OFFICE this'2 3M day day of July, July, 2019. .. ,n. :':···"~,,,,,, ~~~~~~~~~~~~ ,,,, il ‘ : ll . ~~6<-~~.~!:~l'-;. .oz‘fié'v'i’lflr, - ~ -~.~:.-~ ~,[~(.AT)~~ g SHERYL 0- CHANDLER s.§"'-. 2 N SHERYL D. Notary Public, two'C/WMM CHANDLER State of '33; otary Public, State of Texas [Seal] l Texas 5:53.. g ~,;:~of'~~~~$ Comm. Expires 01-29-2022 [Seal] C°mm~ Expires otary Pulgic, in and for affé'o'é'x'igs 01-29-2022 :".. i: """“‘ ''"•"'' Nmarv ID Notary ID 3261561 3261561 The State of Texas Affidavit Affidavit of Lupe Lopez Page 22 437053 EXHIBIT J CAUSE NO. CAUSE NO. DC-16-11118 DC-16-1 1 118 STROM AVIATION, STROM AVIATION, INC. INC. §§ THE DISTRICT IN THE IN COURT DISTRICT COURT §§ Plaintiff, Plaintiff, §§ §§ v. V. §§ §§ ROBINSON AIRCRAFT INTERIORS, ROBINSON AIRCRAFT INTERIORS, §§ INC., INC., et et al. al. §§ DALLAS COUNTY, DALLAS TEXAS COUNTY, TEXAS §§ Defendants, Defendants, §§ §§ v. V. §§ §§ DANIEL G. DANIEL WROLSON G. WROLSON §§ §§ Third-Party Third-Party Defendant. Defendant. §§ 95TH JUDICIAL 95TH JUDICIAL DISTRICT DISTRICT RUTH VERA OF RUTH AFFIDAVIT OF AFFIDAVIT VERA “My name "My RUTH VERA. name isis RUTH am over VERA. II am over the the age age oftwenty-one of twenty-one (21), (21), and am fully and am fully competent competent and and capable capable in in all respects to all respects make this to make this affidavit. affidavit. All All of ofthe the facts facts contained contained within within this this affidavit affidavit are are true true and and correct correct and and are are based based upon my personal upon my personal knowledge. knowledge. 1.1. am aa paralegal II am paralegal for for the the law firm of law firm ofPassman Passman and and Jones, Jones, aa Professional Professional Corporation. Corporation. 2. 2. On July16, On Julyl6, 2019, 2019, II assisted assisted one one of of the firm’s clients, the firm's clients, Robinson Robinson Aircraft Aircraft Interiors, Interiors, Inc. ("RAI") Inc. (“RAI”) in in depositing depositing the sum of$150,000.00 the sum of $150,000.00 into into the the registry registry ofthe of the Court. Court. II also also assisted assisted in in placing aa $150,000.000 placing $ 50,000.000 check 1 made payable check made payable to to Strom Strom Aviation, Aviation, Inc. Inc. (the “Check”) into (the "Check") into the the registry registry of ofthe the Court. Court 3.3. Attached Attached hereto as Exhibit hereto as “1” is Exhibit "1" is aa true true and and correct correct copy copy of of the the District District Clerk's Clerk’s Tender Tender Receipt, Receipt, which which the the District District Clerk Clerk provided when the provided when Check was the Check was placed placed into into the registry of the registry of the the Court. Court. Affidavit of Affidavit ofRuth Ruth Vera Vera Page Page 11 437069 437069 4. Attached hereto as Exhibit “2” is a true and correct copy of an e-mail and attachment I received from Gail Goodwine-Gomez of the Dallas County D'strict Clerk Trust Department, confirming the Clerk’s receipt of $1 0,000.00 o J FURTHER AFFIANT SAYETH NOT. R th Vera, A lant M BEFORE ME, the undersigned authority, n this day personally appeared Ruth Vera, known to me to be the person whose name is subsc 'bed to the above and foregoing instrument, and acknowledged to me that he/she executed the me for the purposes and considerations therein expressed. GIVEN UNDER MY HAND AND SEAL OF OFFICE this ZZRJday of July, 2019. [Seal] , .5 _ ’_ ‘_;é.:.-.,'f.§,",gf,¢ ft: . :3;‘é¥:§ Comm. SHERYL D. ~.;§.’§Notary Public, CHANDLER State of Texas Expires 01-29-2022 The Wiam No'tary Puhllc, in and for State of Texas '-._.,3f‘.\\\‘ Notary ID 3261561 Affidavit of Ruth Vera Page 2 437069 EXHIBIT 11 TENDER RECEIPT " THE STATE OF TEXAS ‘ COUNTY OF DALLAS i . Received of: h .l $0 n To be held In the Registry of the Court in: Cause No. - " I l b The following: V I I ‘.. I 01111.00 WITNESS MY HAND AND SEAL OF OFFICE at Dallas, Texas , this fl fl I fl 2mg day of . A.D. Released to: FELICIA PITRE Per Court Order: District Clerk Dallas nty, Tex Date of Order: . BY Released by: De uty Clerk / Date Released' EXHIBIT 22 Vera, Ruth From: Gail Gomez Sent: Wednesday, July 17, 201 9 8:36 AM To: Vera, Ruth Cc: George Ventjr Subject: DC 16- 11118-D Attachments: DC 16-1 1 1 18 Wire Deposit .pdf Importance: High Good morning, Here is your receipt for the Wire transfer deposit. If you have any questions, please call the Trust Department at (214) 653-7161. Have a wonderful day too. Gail Goodwine-Gomez Dallas County District Clerk Trust Department 600 Commerce St Ste 3-20 Dallas, Tx 75202 m: 214-653-7161 Email: Gail.Gomez@Dallascountyorg 3" fiorr‘ra gave ’ ‘ ‘ flnandal IPraL-Qdas; 1" STROM Avmnon, mc. vs. ROBINSON AIRCRAFF INTERIORS, mo, et al Type OTHER (CIVIL) )er Home 7’7rz‘ ”I‘m V - m? M WV: I . A AL)... k , mind" "I ”a W.» 7" £3... L; On Behalf 0f ROBINSON AIRCRAFT INTERIORS, INC. Expected Fnal Taxpayer ID Disbursement Payer ROBINSON AIRCRAFTINTERIORS, INC. n9 r; Lam v. n . Iistramn V Decreases C3se F-es DEPOSW (FROM PER sow) {e V 07/16/2019 -2019 DCLK nceS oun: SM 3v ' 5-,.“ Bank , 953mm: invoice ipt n's.ement Increasa Decreases esmng QIJEIJ": .Irsements No investments exist for this account. pted 8c nd Click the add icon to add a new investment Ema! Bend 0r Other 301 IcumentS f mum" u, nu, . .. 7/17,:2019 8:13am E