Preview
Filed: 9/17/2021 1:10 PM
JOHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 57360772
By: Shailja Dixit
KEBODEAUX
IS 9/17/2021 2:15 PM
Keith Kebodeaux
Board Certified
Civil Trial Law
jPl-L
V ^ l/\r\>Jl>\_/JL-'JL TV
Casey H, Hargroder
Licensed In Texas and Louisiana
Civil Appellate Law
Personal Injury Trial Law
ASSOCIATES, chargroder@khalaw.com
Texas Board of Legal Specialization LLR
Civil Trial Advocate-
Nat.Board oftrial Advocacy ATTORNEYS AT LAW
LL.M.Taxation 2905 TOCCOA STREET
kkcbodeaux@khalaw.com BEAUMONT,TEXAS 7770.1
PHONE:(409)832-0.147
FACSIMILE:(409)838-0167
www.khalaw.com
September 17,2021
Mr. Andrew J. Clark
ANDREWS MYERS,P.O.
1885 Saint James Place, 15th Floor
Houston, Texas 77056
Via E-file
Via E-mail: aclark@andrewsmvers.com -
Re: Cause No. 21-CV-0568; Triad Electric & Controls, Inc. v. Texas International
Terminals, Ltd.; In the 122"^ Judicial District Court of Galveston County,
Texas; KHA File No.2314
Dear Mr. Clark:
It is unfortunate that I am having to write this letter to you, but I find that it is important
and necessary to confirm our discussions that occurred prior to and after you filed the recent
Rule 11 Agreement on September 15, 2021,in the above-referenced matter.
On tbe morning of Wednesday, September 15, 2021, you contacted me and requested an
extension of time to answer Plaintiff's First Set of Written Discovery Requests to Defendant,
Texas International Terminals, Ltd.("TXIT"), which included Plaintiffs First Set of Request for
Admissions, First Set of Interrogatories, and First Set of Requests for Production. The due date
for TXIT's responses to such written discovery requests from Plaintiff is Friday, September 17,
2021. During the call, you advised me that you needed a two (2) week extension in order to
respond to the outstanding discovery requests due to your busy schedule. My initial verbal
response to you was to extend the courtesy and agree to the two(2) week extension because you
stated to me that in exchange, TXIT would submit a good faith settlement offer during the two
(2) week extension.
However, after initially submitting my agreement to the Rule 11 Agreement via email,
my client advised me that I was not authorized to provide the two (2) week extension for TXIT
to respond to Plaintiffs written discovery requests, and to contact you and rescind the agreement
to the two (2) week extension immediately. Also, your drafted Rule 11 Agreement did not
Mr. Andrew J. Clark
September 17,2021
Page 2
contain TXIT's agreement to submit a good faith settlement offer to Triad during the 2-week
extension period, as you explained in our earlier call.
During our second call at approximately 2:00 p.m. on Wednesday, September 15, 2021,1
advised you that the Rule 11 Agreement had to be rescinded because I had no authority to grant
your requested 2-week extension, and I had learned ofsome negative and direct communications
that had been made between the company representatives of Triad and TXIT,of which you and I
were unaware, after TXIT received the outstanding discovery requests from Triad on August 18,
2021. Evidently, the direct communications between Triad's representatives and TXIT's
representatives had created tensions between them resulting in my client's refusal to grant any
extensions regarding discovery.
During our 2:00 p.m. call on Wednesday, September 15, 2021,1 also presented you with
an alternative proposal for granting the two (2) week extension, which included TXIT agreeing
to provide a good faith settlement offer by the close of business on September 17, 2021, at which
time a two (2) week extension would be granted to TXIT to respond to Plaintiffs outstanding
discovery requests on or before October 1, 2021. During that call, you advised me that you
would contact your client regarding the newly presented extension offer and would return my
call by the end of the business day of September 15, 2021. You also requested me not to send
anything in writing to you regarding the rescinded Rule 11 Agreement until you talked to Tim
Ross and your client.
However, instead of making a return call to me and advising or discussing the matter
further, you filed the Rule 11 Agreement at approximately 5:04 p.m. on Wednesday, September
15, 2021 (which is attached as Exhibit "A"). At no time did I approve the filing of the Rule 11
Agreement or provide you with consent, as I had instructed you that it was withdrawn and
rescinded during our telephone conference prior thereto. Accordingly, the Rule 11 Agreement
that was filed with the Court on September 15, 2021 (Exhibit "A"), was filed without Plaintiffs
authority and without consent of the Plaintiff or its counsel, as it had effectively been withdrawn.
I again conferred with you via telephone on September 15, 2021, regarding your filing of
the attached Rule 11 Agreement, but you refused to withdraw it, claiming it was correctly filed,
despite my prior communication with you that it was withdrawn and rescinded. In turn, I
advised you that I would notify the Court of this situation, so that the Court was made aware of
the invalid Rule 11 Agreement that was incorrectly filed. Also, during this third telephone call
on September 15, 2021, you suggested a solution to this situation wherein Triad would agree to
grant a one-week extension (or by September 24, 2021) for TXIT to respond to Triad's written
discovery requests, provided that TXIT agrees to also provide a good faith settlement offer by
the close of business on September 24,2021 as well.
On the morning of September 16, 2021, I advised you via email that my client was
agreeable to the one-week extension, if TXIT also agreed to present Triad with a good faith
settlement offer by the close of business on Friday, September 24, 2021. You responded shortly
Mr. Andrew J. Clark
September 17, 2021
Page 3
thereafter via email saying you would check with your client and get back with me. However,
you called me on the afternoon of September 16, 2021, and during our conversation you advised
me that you were unable to make contact with your client to secure your client's final approval
of the one-week extension and its agreement to submit the good faith settlement offer by
September 24, 2021. I responded by saying that was unfortunate, and 1 told you that I would
advise the Court of the situation, especially since you filed an invalid Rule 11 Agreement
without consent from me or my client and refused to withdraw it.
It is unfortunate that I have to copy the Court with this letter advising of this situation.
However, should you choose to file a Motion to Enforce the Rule 11 Agreement (Exhibit "A"),
the Court should be aware of the circumstances. Also, please know that I will challenge any
Motion to Enforce the Rule 11 Agreement filed without authority or consent. If necessary, we
will request a status conference or hearing with the Court to intervene regarding this disputed
Rule 11 Agreement.
Should you wish to discuss this matter further, please feel free to call me at any time.
Thank you for your time and consideration.
Sincerely,
Casey H. Hargroder
CHH/cmw
Enclosure: Exhibit "A"
cc: Honorable John Ellisor
122"'' District Court
600 59th Street, Suite 4304
Galvesion, Texas 77551
ViaE-nie
Mr. Timothy C. Ross
ANDREWS MYERS,P.C.
1885 Saint James Place, 15th Floor
Houston, Texas 77056
Via E-file
Via E-mail: tr(m@andrewsm\ers.com
Filed; 9/15/2021 5:04 PM
21-CV-0568 JOHN D. KINARD - District Clerk
Gaiveston County, Texas
Envelope No. 57291659
Angela Broady Gaiveston County - 122nd District Court
From: Andrew Ciark
Sent: Wednesday, September 15, 2021 2:02 PM
To: chargroder@khalaw.com
Cc: Timothy Ross; Angela Broady;"Charlene Wheeler"
Subject: RE: Rule 11 Agreement // Triad Electric & Controls, Inc. v. Texas International Terminals,
Ltd., Cause No. 21-CV-05668, in the 122nd Judicial District Court of Gaiveston County,
Texas
Okay—we are agreed. Thanks, Casey.
Andrew J. Clark
Attorney
Andrews Myers|Attorneys at Law
TEL: 713-351-0333
EMAIL: adafk(5)andfewsinvers.com
WEB: www.andrewsmyefs.com
CONFlOENTiALlTY NOTICE: Andrews Myers Is a law firm. This electronic transmission and any attactiments constitute conrrdential
Information wtiich is inlended only for the named recipienl(s) and may be legally privileged. If you have received this communication in
error, please contact the sender immediately Any disclosure, copying, disiribulion or the taking of any action coticeming the coniems of
this communication by anyone other than the named recipienKs) is strictly prohibited
From: chargroder@khalaw.com (mailto:chargroder@khalaw.com]
Sent: Wednesday,September 15, 2021 1:59 PM
To: Andrew Clark
Cc: Timothy Ross ; Angela Broady ;'Charlene Wheeler'
Subject: RE: Rule 11 Agreement // Triad Electric & Controls, Inc. v. Texas International Terminals, Ltd., Cause No. 21-CV-
05668, in the 122nd Judicial District Court of Gaiveston County, Texas
Andy:
Triad agrees to the Rule 11 Agreement you provided below.
Thanks.
Casey H. Hargroder
Parhter|Atlorney atLaw
KEBODEAUX,HARGRODER & ASSOCIATES,L.L.P.
2905 Toccoa Street
Beaumont,TX 77703
(409)832-0347 ext. 6 - Telephone
(409)838-0167 - Facsimile
chargroder@khalaw.com
www.khalaw.com
*Licensed in Texas and Louisiana EXHIBIT
A
STATEMENT OF CONFIDENTIALITY - ATTORNEY-CLIENT COMMUNICATION and/or ATTORNEY WORK PRODUCT:The
above message may be protected by the attorney-client privilege and/or attorney work product. The contents of this e-
mail and its attachments, if any, are intended solely for the addressee(s) hereof. If you are not the named addressee(s),
or if this message has been addressed to you in error, you are directed NOT TO READ, DISCLOSE, REPRODUCE,
DISTRIBUTE, DISSEMINATE or OTHERWISE USE THIS TRANSMISSION. Delivery of this message to any person other than
the Intended reclplent(s) is not intended In any way to waive privilege and confidentiality. Inform the sender by return e-
mall that you have received the message in error, then DELETE the message and Its attachments. If any. Thank you.
From: Andrew Clark
Sent: Wednesday,September 15, 202111:18 AM
To: chargroder@khalaw.com
Cc: Timothy Ross : Angela Broady
Subject: Rule 11 Agreement // Triad Electric 8i Controls, Inc. v. Texas International Terminals, Ltd., Cause No. 21-CV-
05668,In the 122nd Judicial District Court of Galveston County, Texas
Rule 11 Agreement
Casey,
As we discussed. Plaintiff Triad Electric & Controls, Inc. agrees to a two-week extension on Defendant Texas
International Terminals, Ltd.'s deadline to respond and object to Plaintiff's First Set of Interrogatories, Requests for
Production, and Requests for Admission.
The new,agreed-upon deadline for Texas International Terminals, Ltd. to respond and object to Plaintiff's First Set of
Interrogatories, Requests for Production, and Requests for Admission will now be Fridav. October 1.2021.
If this accurately reflects our agreement, please respond to this email with "Agree" or "Agreed" and this email exchange
will be treated as a Rule 11 Agreement per the Texas Rules of Civil Procedure.
Thanks,
Andy
Andrew J. Clark
Attorney
Andrews Myers | Attorneys at Law
Houston I Austin
1885 Saint James Place. IS"" Floor, Houston. TX 77056
TEL: 713-351-0338
FAX: 713-351-0394
EFAX: 832-460-7859
EMAIL: aclark@andrewsmvers.com
WEB: www.andrewsmvers.com
CONSTRUCTION j TRIALS j REAL ESTATE
| CORPORATE j ENERGY j EMPLOYMENT
| BANKRUPTCY
CONFIDENTIALITY NOTICE: Andrews Myers is a law firm This electronic transmission and any attachments constitute confidential
information which is intended only for the named recipient(s) and may be legally privileged. If you have received this communication in
error, please contact the sender immediately. Any disclosuie. copying, distribution or the taking of any action concerning the contents of
this communication by anyone other than the named recipient(s) is strictly prohibited.
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.
Angela Broady on behalf of Andrew Clark
Bar No. 24101624
abroady@andrewsmyers.com
Envelope ID: 57291659
Status as of 9/16/2021 7:57 AM GST
Associated Case Party: Texas International Terminals, Ltd.
Name BarNumber Email TimestampSubmitted Status
Timothy C.Ross tross@andrewsmyers.com 9/15/2021 5:04:40 PM SENT
Andrew JamesClark aclark@andrewsmyers.com 9/15/2021 5:04:40 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Charlene Wheeler cwheeler@khalaw.com 9/15/2021 5:04:40 PM SENT
Kathy Bocco kbocco@andrewsmyers.com 9/15/2021 5:04:40 PM SENT
Nicole G.Nicholas nnicholas@khalaw.com 9/15/2021 5:04:40 PM SENT
Associated Case Party: Triad Electric & Controls, Inc.
Name BarNumber Email TimestampSubmitted Status
Casey Hargroder 24050718 chargroder@khalaw.com 9/15/2021 5:04:40 PM SENT
Sarah Irwin 24116557 sirwin@thomasjhenrylaw.com 9/15/2021 5:04:40 PM SENT
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.
Charlene Wheeler on behalf of Casey Hargroder
Bar No. 24050718
cwheeler@khalaw.com
Envelope ID: 57360772
Status as of 9/17/2021 2:15 PM CST
Associated Case Party: Triad Electric & Controls, Inc.
Name BarNumber Email TimestampSubmitted Status
Casey Hargroder 24050718 chargroder@khalaw.com 9/17/2021 1:10:30 PM SENT
Associated Case Party: Texas International Terminals, Ltd.
Name BarNumber Email TimestampSubmitted Status
Timothy C.Ross tross@andrewsmyers.com 9/17/2021 1:10:30 PM SENT
Andrew JamesClark aclark@andrewsmyers.com 9/17/2021 1:10:30 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Charlene Wheeler cwheeler@khalaw.com 9/17/2021 1:10:30 PM SENT
Kathy Bocco kbocco@andrewsmyers.com 9/17/2021 1:10:30 PM SENT
Nicole G.Nicholas nnicholas@khalaw.com 9/17/2021 1:10:30 PM SENT
Preview
Filed: 9/17/2021 1:10 PM JOHN D. KINARD - District Clerk Galveston County, Texas Envelope No. 57360772 By: Shailja Dixit KEBODEAUX IS 9/17/2021 2:15 PM Keith Kebodeaux Board Certified Civil Trial Law jPl-L V ^ l/\r\>Jl>\_/JL-'JL TV Casey H, Hargroder Licensed In Texas and Louisiana Civil Appellate Law Personal Injury Trial Law ASSOCIATES, chargroder@khalaw.com Texas Board of Legal Specialization LLR Civil Trial Advocate- Nat.Board oftrial Advocacy ATTORNEYS AT LAW LL.M.Taxation 2905 TOCCOA STREET kkcbodeaux@khalaw.com BEAUMONT,TEXAS 7770.1 PHONE:(409)832-0.147 FACSIMILE:(409)838-0167 www.khalaw.com September 17,2021 Mr. Andrew J. Clark ANDREWS MYERS,P.O. 1885 Saint James Place, 15th Floor Houston, Texas 77056 Via E-file Via E-mail: aclark@andrewsmvers.com - Re: Cause No. 21-CV-0568; Triad Electric & Controls, Inc. v. Texas International Terminals, Ltd.; In the 122"^ Judicial District Court of Galveston County, Texas; KHA File No.2314 Dear Mr. Clark: It is unfortunate that I am having to write this letter to you, but I find that it is important and necessary to confirm our discussions that occurred prior to and after you filed the recent Rule 11 Agreement on September 15, 2021,in the above-referenced matter. On tbe morning of Wednesday, September 15, 2021, you contacted me and requested an extension of time to answer Plaintiff's First Set of Written Discovery Requests to Defendant, Texas International Terminals, Ltd.("TXIT"), which included Plaintiffs First Set of Request for Admissions, First Set of Interrogatories, and First Set of Requests for Production. The due date for TXIT's responses to such written discovery requests from Plaintiff is Friday, September 17, 2021. During the call, you advised me that you needed a two (2) week extension in order to respond to the outstanding discovery requests due to your busy schedule. My initial verbal response to you was to extend the courtesy and agree to the two(2) week extension because you stated to me that in exchange, TXIT would submit a good faith settlement offer during the two (2) week extension. However, after initially submitting my agreement to the Rule 11 Agreement via email, my client advised me that I was not authorized to provide the two (2) week extension for TXIT to respond to Plaintiffs written discovery requests, and to contact you and rescind the agreement to the two (2) week extension immediately. Also, your drafted Rule 11 Agreement did not Mr. Andrew J. Clark September 17,2021 Page 2 contain TXIT's agreement to submit a good faith settlement offer to Triad during the 2-week extension period, as you explained in our earlier call. During our second call at approximately 2:00 p.m. on Wednesday, September 15, 2021,1 advised you that the Rule 11 Agreement had to be rescinded because I had no authority to grant your requested 2-week extension, and I had learned ofsome negative and direct communications that had been made between the company representatives of Triad and TXIT,of which you and I were unaware, after TXIT received the outstanding discovery requests from Triad on August 18, 2021. Evidently, the direct communications between Triad's representatives and TXIT's representatives had created tensions between them resulting in my client's refusal to grant any extensions regarding discovery. During our 2:00 p.m. call on Wednesday, September 15, 2021,1 also presented you with an alternative proposal for granting the two (2) week extension, which included TXIT agreeing to provide a good faith settlement offer by the close of business on September 17, 2021, at which time a two (2) week extension would be granted to TXIT to respond to Plaintiffs outstanding discovery requests on or before October 1, 2021. During that call, you advised me that you would contact your client regarding the newly presented extension offer and would return my call by the end of the business day of September 15, 2021. You also requested me not to send anything in writing to you regarding the rescinded Rule 11 Agreement until you talked to Tim Ross and your client. However, instead of making a return call to me and advising or discussing the matter further, you filed the Rule 11 Agreement at approximately 5:04 p.m. on Wednesday, September 15, 2021 (which is attached as Exhibit "A"). At no time did I approve the filing of the Rule 11 Agreement or provide you with consent, as I had instructed you that it was withdrawn and rescinded during our telephone conference prior thereto. Accordingly, the Rule 11 Agreement that was filed with the Court on September 15, 2021 (Exhibit "A"), was filed without Plaintiffs authority and without consent of the Plaintiff or its counsel, as it had effectively been withdrawn. I again conferred with you via telephone on September 15, 2021, regarding your filing of the attached Rule 11 Agreement, but you refused to withdraw it, claiming it was correctly filed, despite my prior communication with you that it was withdrawn and rescinded. In turn, I advised you that I would notify the Court of this situation, so that the Court was made aware of the invalid Rule 11 Agreement that was incorrectly filed. Also, during this third telephone call on September 15, 2021, you suggested a solution to this situation wherein Triad would agree to grant a one-week extension (or by September 24, 2021) for TXIT to respond to Triad's written discovery requests, provided that TXIT agrees to also provide a good faith settlement offer by the close of business on September 24,2021 as well. On the morning of September 16, 2021, I advised you via email that my client was agreeable to the one-week extension, if TXIT also agreed to present Triad with a good faith settlement offer by the close of business on Friday, September 24, 2021. You responded shortly Mr. Andrew J. Clark September 17, 2021 Page 3 thereafter via email saying you would check with your client and get back with me. However, you called me on the afternoon of September 16, 2021, and during our conversation you advised me that you were unable to make contact with your client to secure your client's final approval of the one-week extension and its agreement to submit the good faith settlement offer by September 24, 2021. I responded by saying that was unfortunate, and 1 told you that I would advise the Court of the situation, especially since you filed an invalid Rule 11 Agreement without consent from me or my client and refused to withdraw it. It is unfortunate that I have to copy the Court with this letter advising of this situation. However, should you choose to file a Motion to Enforce the Rule 11 Agreement (Exhibit "A"), the Court should be aware of the circumstances. Also, please know that I will challenge any Motion to Enforce the Rule 11 Agreement filed without authority or consent. If necessary, we will request a status conference or hearing with the Court to intervene regarding this disputed Rule 11 Agreement. Should you wish to discuss this matter further, please feel free to call me at any time. Thank you for your time and consideration. Sincerely, Casey H. Hargroder CHH/cmw Enclosure: Exhibit "A" cc: Honorable John Ellisor 122"'' District Court 600 59th Street, Suite 4304 Galvesion, Texas 77551 ViaE-nie Mr. Timothy C. Ross ANDREWS MYERS,P.C. 1885 Saint James Place, 15th Floor Houston, Texas 77056 Via E-file Via E-mail: tr(m@andrewsm\ers.com Filed; 9/15/2021 5:04 PM 21-CV-0568 JOHN D. KINARD - District Clerk Gaiveston County, Texas Envelope No. 57291659 Angela Broady Gaiveston County - 122nd District Court From: Andrew Ciark Sent: Wednesday, September 15, 2021 2:02 PM To: chargroder@khalaw.com Cc: Timothy Ross; Angela Broady;"Charlene Wheeler" Subject: RE: Rule 11 Agreement // Triad Electric & Controls, Inc. v. Texas International Terminals, Ltd., Cause No. 21-CV-05668, in the 122nd Judicial District Court of Gaiveston County, Texas Okay—we are agreed. Thanks, Casey. Andrew J. Clark Attorney Andrews Myers|Attorneys at Law TEL: 713-351-0333 EMAIL: adafk(5)andfewsinvers.com WEB: www.andrewsmyefs.com CONFlOENTiALlTY NOTICE: Andrews Myers Is a law firm. This electronic transmission and any attactiments constitute conrrdential Information wtiich is inlended only for the named recipienl(s) and may be legally privileged. If you have received this communication in error, please contact the sender immediately Any disclosure, copying, disiribulion or the taking of any action coticeming the coniems of this communication by anyone other than the named recipienKs) is strictly prohibited From: chargroder@khalaw.com (mailto:chargroder@khalaw.com] Sent: Wednesday,September 15, 2021 1:59 PM To: Andrew Clark Cc: Timothy Ross ; Angela Broady ;'Charlene Wheeler' Subject: RE: Rule 11 Agreement // Triad Electric & Controls, Inc. v. Texas International Terminals, Ltd., Cause No. 21-CV- 05668, in the 122nd Judicial District Court of Gaiveston County, Texas Andy: Triad agrees to the Rule 11 Agreement you provided below. Thanks. Casey H. Hargroder Parhter|Atlorney atLaw KEBODEAUX,HARGRODER & ASSOCIATES,L.L.P. 2905 Toccoa Street Beaumont,TX 77703 (409)832-0347 ext. 6 - Telephone (409)838-0167 - Facsimile chargroder@khalaw.com www.khalaw.com *Licensed in Texas and Louisiana EXHIBIT A STATEMENT OF CONFIDENTIALITY - ATTORNEY-CLIENT COMMUNICATION and/or ATTORNEY WORK PRODUCT:The above message may be protected by the attorney-client privilege and/or attorney work product. The contents of this e- mail and its attachments, if any, are intended solely for the addressee(s) hereof. If you are not the named addressee(s), or if this message has been addressed to you in error, you are directed NOT TO READ, DISCLOSE, REPRODUCE, DISTRIBUTE, DISSEMINATE or OTHERWISE USE THIS TRANSMISSION. Delivery of this message to any person other than the Intended reclplent(s) is not intended In any way to waive privilege and confidentiality. Inform the sender by return e- mall that you have received the message in error, then DELETE the message and Its attachments. If any. Thank you. From: Andrew Clark Sent: Wednesday,September 15, 202111:18 AM To: chargroder@khalaw.com Cc: Timothy Ross : Angela Broady Subject: Rule 11 Agreement // Triad Electric 8i Controls, Inc. v. Texas International Terminals, Ltd., Cause No. 21-CV- 05668,In the 122nd Judicial District Court of Galveston County, Texas Rule 11 Agreement Casey, As we discussed. Plaintiff Triad Electric & Controls, Inc. agrees to a two-week extension on Defendant Texas International Terminals, Ltd.'s deadline to respond and object to Plaintiff's First Set of Interrogatories, Requests for Production, and Requests for Admission. The new,agreed-upon deadline for Texas International Terminals, Ltd. to respond and object to Plaintiff's First Set of Interrogatories, Requests for Production, and Requests for Admission will now be Fridav. October 1.2021. If this accurately reflects our agreement, please respond to this email with "Agree" or "Agreed" and this email exchange will be treated as a Rule 11 Agreement per the Texas Rules of Civil Procedure. Thanks, Andy Andrew J. Clark Attorney Andrews Myers | Attorneys at Law Houston I Austin 1885 Saint James Place. IS"" Floor, Houston. TX 77056 TEL: 713-351-0338 FAX: 713-351-0394 EFAX: 832-460-7859 EMAIL: aclark@andrewsmvers.com WEB: www.andrewsmvers.com CONSTRUCTION j TRIALS j REAL ESTATE | CORPORATE j ENERGY j EMPLOYMENT | BANKRUPTCY CONFIDENTIALITY NOTICE: Andrews Myers is a law firm This electronic transmission and any attachments constitute confidential information which is intended only for the named recipient(s) and may be legally privileged. If you have received this communication in error, please contact the sender immediately. Any disclosuie. copying, distribution or the taking of any action concerning the contents of this communication by anyone other than the named recipient(s) is strictly prohibited. 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. Angela Broady on behalf of Andrew Clark Bar No. 24101624 abroady@andrewsmyers.com Envelope ID: 57291659 Status as of 9/16/2021 7:57 AM GST Associated Case Party: Texas International Terminals, Ltd. Name BarNumber Email TimestampSubmitted Status Timothy C.Ross tross@andrewsmyers.com 9/15/2021 5:04:40 PM SENT Andrew JamesClark aclark@andrewsmyers.com 9/15/2021 5:04:40 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Charlene Wheeler cwheeler@khalaw.com 9/15/2021 5:04:40 PM SENT Kathy Bocco kbocco@andrewsmyers.com 9/15/2021 5:04:40 PM SENT Nicole G.Nicholas nnicholas@khalaw.com 9/15/2021 5:04:40 PM SENT Associated Case Party: Triad Electric & Controls, Inc. Name BarNumber Email TimestampSubmitted Status Casey Hargroder 24050718 chargroder@khalaw.com 9/15/2021 5:04:40 PM SENT Sarah Irwin 24116557 sirwin@thomasjhenrylaw.com 9/15/2021 5:04:40 PM SENT 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. Charlene Wheeler on behalf of Casey Hargroder Bar No. 24050718 cwheeler@khalaw.com Envelope ID: 57360772 Status as of 9/17/2021 2:15 PM CST Associated Case Party: Triad Electric & Controls, Inc. Name BarNumber Email TimestampSubmitted Status Casey Hargroder 24050718 chargroder@khalaw.com 9/17/2021 1:10:30 PM SENT Associated Case Party: Texas International Terminals, Ltd. Name BarNumber Email TimestampSubmitted Status Timothy C.Ross tross@andrewsmyers.com 9/17/2021 1:10:30 PM SENT Andrew JamesClark aclark@andrewsmyers.com 9/17/2021 1:10:30 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Charlene Wheeler cwheeler@khalaw.com 9/17/2021 1:10:30 PM SENT Kathy Bocco kbocco@andrewsmyers.com 9/17/2021 1:10:30 PM SENT Nicole G.Nicholas nnicholas@khalaw.com 9/17/2021 1:10:30 PM SENT