On July 01, 2021 a
Request,Application
was filed
involving a dispute between
South Shore Harbour Commercial Maintenance Association, Inc.,
and
Globix Marina, Llc,
for Contract - Other
in the District Court of Galveston County.
Preview
Filed: 6/30/2022 9:45 AM
JOHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 65918491
By: Rolande Kain
6/30/2022 10:07 AM
CAUSE NO. 21-CV-0956
SOUTH SHORE HARBOUR § IN THE DISTRICT COURT OF
COMMERCIAL MAINTAINANCE §
ASSOCIATION, INC., §
§
Plaintiff, §
§
vs § GALVESTON COUNTY, TEXAS
§
§
GLOBIX MARINA, LLC, §
§
Defendant. § 122ND DISTRICT COURT
OPPOSED SUPPLEMENTAL REQUEST FOR ORAL HEARING ON DEFENDANT’S
MOTION FOR NEW TRIAL AND TO VACATE
COMES NOW, Defendant, Globix Marina, LLC, and files this Opposed Supplemental Request for
Oral Hearing on its Motion for New Trial and to Vacate previously filed in the above matter.
Defendant’s Counsel has conferred with Plaintiff’s Counsel on this matter and counsel is opposed
to having this matter set for oral hearing. See email correspondence attached hereto as Exhibit 1. Plaintiff’s
counsel continues to be opposed to the Motion for New Trial and to Vacate as stated in the Certificate of
Conference and Exhibit 2 of the Motion.
Despite Plaintiff’s opposition, Defendant again requests this matter be set for oral hearing at the
earliest date and convenience of this Court.
Respectfully submitted,
MURRAY | LOBB, PLLC
By: /s/ Patrick C. Bates
Patrick C. Bates
State Bar No. 24068882
2200 Space Park Drive, Suite 350
Houston, Texas 77058
Tel: (281) 488-0630
Fax: (281) 488-2039
Email: pbates@murray-lobb.com
ATTORNEYS FOR DEFENDANT GLOBIX
MARINA, LLC
1
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the above and foregoing instrument has been served upon
all counsel of record pursuant to Rules 21 and 21a of the TEXAS RULES OF CIVIL PROCEDURE on June 30,
2022.
VIA Electronic Service
TRISHA TAYLOR FARINE
17044 El Camino Real
Houston, Texas 77058
(281) 480-6888
(281) 218-9151 – facsimile
farine.filing@daughtryfarine.com
/s/ Patrick C. Bates
Patrick C. Bates
2
Tuesday, June 28, 2022 at 16:03:43 Central Daylight Time
Subject: RE: South Shore / Globix - conference re: oral hearing request
Date: Tuesday, June 28, 2022 at 3:00:06 PM Central Daylight Time
From: Trisha Farine
To: Patrick Bates
CC: Judy Updegraff
AFachments: image002.jpg, image003.jpg, image004.jpg, image005.png
Please put me down as opposed to an oral hearing. I don’t believe it’s necessary.
Trisha Taylor Farine
www.daughtryfarine.com
17044 El Camino Real
Houston, Texas 77058
281-480-6888 (phone)
281-218-9151 (fax)
1-866-480-6888 (toll free)
]arine@daughtryfarine.com
This confiden`al email may be lawyer-client or aaorney work product privileged. It is covered by Electronic Communica`ons Privacy Act.
If you are not the intended recipient, you may not disclose, print, copy or disseminate this informa`on. This firm does not give tax
advice. This communica`on does not reflect an inten`on by the sender or his client to conduct a transac`on or make any agreement by
electronic means. Nothing contained in this email or in any aaachment shall sa`sfy the requirements for a wri`ng or cons`tute a
contract or electronic signature under the Electronic Signatures in Global & Na`onal Commerce Act or in Uniform Electronic Transac`ons
Act or any statute governing electronic transac`ons. STATUTORY DEBT COLLECTION NOTICE. This law firm is a “debt collector,” as defined
by law. Accordingly, you are hereby advised that one of the purposes of this email may be to effectuate the collec`on of a debt and any
informa`on obtained will be used for that purpose. Recipients of emails sent in an aaempt to collect a debt may opt out of email
communica`on by replying “OPT OUT” to this message.
From: Patrick Bates
Sent: Tuesday, June 28, 2022 2:50 PM
To: Trisha Farine <]arine@daughtryfarine.com>
Cc: Judy Updegraff
Subject: South Shore / Globix - conference re: oral hearing request
Hello Trisha and good amernoon.
I requested an oral hearing on Defendant’s Mo`on for New Trial and To Vacate. I noted in the Mo`on to
Vacate that you opposed the relief.
However, I did not ask if you are opposed, unopposed, or agreed to my request for oral hearing.
Page 1 of 2
EXHIBIT 1
Please let me know if you are agreed, opposed, or unopposed to my request for oral hearing.
Patrick
Patrick C. Bates | SENIOR ASSOCIATE
2200 Space Park Drive, Suite 350, Houston, Texas 77058
o: (281) 488-0630 | d: (281) 938-1916
pbates@murray-lobb.com | www.murray-lobb.com
Page 2 of 2
EXHIBIT 1
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.
Judy Updegraff on behalf of Patrick Bates
Bar No. 24068882
jupdegraff@murray-lobb.com
Envelope ID: 65918491
Status as of 6/30/2022 10:08 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Patrick C.Bates pbates@murray-lobb.com 6/30/2022 9:45:33 AM SENT
Judy Updegraff jupdegraff@murray-lobb.com 6/30/2022 9:45:33 AM SENT
Associated Case Party: South Shore Harbour Commercial Maintenance Association,
Inc.
Name BarNumber Email TimestampSubmitted Status
Trisha Farine Farine.filing@daughtryfarine.com 6/30/2022 9:45:33 AM SENT
Associated Case Party: Globix Marina, LLC
Name BarNumber Email TimestampSubmitted Status
Patrick Bates pbates@murray-lobb.com 6/30/2022 9:45:33 AM SENT
ZULFIQAR NPRASLA ZNP@praslalaw.com 6/30/2022 9:45:33 AM SENT
Document Filed Date
June 30, 2022
Case Filing Date
July 01, 2021
Category
Contract - Other
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filed: 6/30/2022 9:45 AM JOHN D. KINARD - District Clerk Galveston County, Texas Envelope No. 65918491 By: Rolande Kain 6/30/2022 10:07 AM CAUSE NO. 21-CV-0956 SOUTH SHORE HARBOUR § IN THE DISTRICT COURT OF COMMERCIAL MAINTAINANCE § ASSOCIATION, INC., § § Plaintiff, § § vs § GALVESTON COUNTY, TEXAS § § GLOBIX MARINA, LLC, § § Defendant. § 122ND DISTRICT COURT OPPOSED SUPPLEMENTAL REQUEST FOR ORAL HEARING ON DEFENDANT’S MOTION FOR NEW TRIAL AND TO VACATE COMES NOW, Defendant, Globix Marina, LLC, and files this Opposed Supplemental Request for Oral Hearing on its Motion for New Trial and to Vacate previously filed in the above matter. Defendant’s Counsel has conferred with Plaintiff’s Counsel on this matter and counsel is opposed to having this matter set for oral hearing. See email correspondence attached hereto as Exhibit 1. Plaintiff’s counsel continues to be opposed to the Motion for New Trial and to Vacate as stated in the Certificate of Conference and Exhibit 2 of the Motion. Despite Plaintiff’s opposition, Defendant again requests this matter be set for oral hearing at the earliest date and convenience of this Court. Respectfully submitted, MURRAY | LOBB, PLLC By: /s/ Patrick C. Bates Patrick C. Bates State Bar No. 24068882 2200 Space Park Drive, Suite 350 Houston, Texas 77058 Tel: (281) 488-0630 Fax: (281) 488-2039 Email: pbates@murray-lobb.com ATTORNEYS FOR DEFENDANT GLOBIX MARINA, LLC 1 CERTIFICATE OF SERVICE I certify that a true and correct copy of the above and foregoing instrument has been served upon all counsel of record pursuant to Rules 21 and 21a of the TEXAS RULES OF CIVIL PROCEDURE on June 30, 2022. VIA Electronic Service TRISHA TAYLOR FARINE 17044 El Camino Real Houston, Texas 77058 (281) 480-6888 (281) 218-9151 – facsimile farine.filing@daughtryfarine.com /s/ Patrick C. Bates Patrick C. Bates 2 Tuesday, June 28, 2022 at 16:03:43 Central Daylight Time Subject: RE: South Shore / Globix - conference re: oral hearing request Date: Tuesday, June 28, 2022 at 3:00:06 PM Central Daylight Time From: Trisha Farine To: Patrick Bates CC: Judy Updegraff AFachments: image002.jpg, image003.jpg, image004.jpg, image005.png Please put me down as opposed to an oral hearing. I don’t believe it’s necessary. Trisha Taylor Farine www.daughtryfarine.com 17044 El Camino Real Houston, Texas 77058 281-480-6888 (phone) 281-218-9151 (fax) 1-866-480-6888 (toll free) ]arine@daughtryfarine.com This confiden`al email may be lawyer-client or aaorney work product privileged. It is covered by Electronic Communica`ons Privacy Act. If you are not the intended recipient, you may not disclose, print, copy or disseminate this informa`on. This firm does not give tax advice. This communica`on does not reflect an inten`on by the sender or his client to conduct a transac`on or make any agreement by electronic means. Nothing contained in this email or in any aaachment shall sa`sfy the requirements for a wri`ng or cons`tute a contract or electronic signature under the Electronic Signatures in Global & Na`onal Commerce Act or in Uniform Electronic Transac`ons Act or any statute governing electronic transac`ons. STATUTORY DEBT COLLECTION NOTICE. This law firm is a “debt collector,” as defined by law. Accordingly, you are hereby advised that one of the purposes of this email may be to effectuate the collec`on of a debt and any informa`on obtained will be used for that purpose. Recipients of emails sent in an aaempt to collect a debt may opt out of email communica`on by replying “OPT OUT” to this message. From: Patrick Bates Sent: Tuesday, June 28, 2022 2:50 PM To: Trisha Farine <]arine@daughtryfarine.com> Cc: Judy Updegraff Subject: South Shore / Globix - conference re: oral hearing request Hello Trisha and good amernoon. I requested an oral hearing on Defendant’s Mo`on for New Trial and To Vacate. I noted in the Mo`on to Vacate that you opposed the relief. However, I did not ask if you are opposed, unopposed, or agreed to my request for oral hearing. Page 1 of 2 EXHIBIT 1 Please let me know if you are agreed, opposed, or unopposed to my request for oral hearing. Patrick Patrick C. Bates | SENIOR ASSOCIATE 2200 Space Park Drive, Suite 350, Houston, Texas 77058 o: (281) 488-0630 | d: (281) 938-1916 pbates@murray-lobb.com | www.murray-lobb.com Page 2 of 2 EXHIBIT 1 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. Judy Updegraff on behalf of Patrick Bates Bar No. 24068882 jupdegraff@murray-lobb.com Envelope ID: 65918491 Status as of 6/30/2022 10:08 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Patrick C.Bates pbates@murray-lobb.com 6/30/2022 9:45:33 AM SENT Judy Updegraff jupdegraff@murray-lobb.com 6/30/2022 9:45:33 AM SENT Associated Case Party: South Shore Harbour Commercial Maintenance Association, Inc. Name BarNumber Email TimestampSubmitted Status Trisha Farine Farine.filing@daughtryfarine.com 6/30/2022 9:45:33 AM SENT Associated Case Party: Globix Marina, LLC Name BarNumber Email TimestampSubmitted Status Patrick Bates pbates@murray-lobb.com 6/30/2022 9:45:33 AM SENT ZULFIQAR NPRASLA ZNP@praslalaw.com 6/30/2022 9:45:33 AM SENT