Preview
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