Preview
FILED
7/28/2021 9:49 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Terri Kilgore DEPUTY
CAUSE NO. DC-19-00359
BRANDIE HARRIS, INDIVIDUALLY IN THE DISTRICT COURT
AND AS HEIR AND REPRESENTATIVE
OF THE ESTATE OF NEIL HARRIS
AND AS NEXT FRIEND OF MINORS,
OH AH AND BH
VS. 68TH JUDICIAL DISTRICT
SB PREMIUM, LLC D/B/A SUICIDE
BUNNY, TIFFANY RESHAM, LARRY
SCOTT GRESHAM, SB PRODUCTS,
SUICIDE BUNNY, WAGES AND WHITE
LION INVESTMENTS, LLC D/B/A
TRITON DISTRIBUTION, WHITE LION
INVESTMENTS, LLC D/B/A TRITON
DISTRIBUTION, SCS VAPE, LLC,
VAPEWILD WHOLESALE, INC. F/K/A
WOLEPACK WHOLESALE, INC. DALLAS COUNTY, TEXAS
PLAINTIFF’S RESPONSE TO DEFENDANTS’ JOINT MOTION FOR CONTINUANCE
OF HEARING TO RE-OPEN DISCOVERY
COMES NOW, Plaintiff Brandie Harris, in the above-styled case and files this Response
to Defendants’ Joint Motion for Continuance of Hearing to Re-Open Discovery. In support thereof,
Plaintiff shows the Court as follows:
SUMMARY OF THE ARGUMENT
l. Defendants’ Motion for Continuance asks this Court to abstain from resolving the instant
discovery dispute, and instead wait to set the matter for hearing until after Defendants’
Writ of Mandamus has been briefed, argued, and decided. This is a clear attempt to fiIrther
delay justice and finality to the Harris family, Who lost their husband and father over three
years ago.
2. Defendants’ Motion is devoid of any legal authority to support its request. Further,
Defendants’ Motion Wholly fails to articulate hOW it Will be prejudiced if the Motion to
Reopen is heard as scheduled. Defendants fail to establish that any resolution of the Writ
of Mandamus would render the Motion to Reopen moot, nor do Defendants establish that
participating in reasonable discovery would be an unfair burden. Accordingly, the Court
should deny Defendants’ Motion for Continuance.
BACKGROUND
3. On April 26, 2021, this Court denied Defendants’ Motion to Strike the First Amended
Complaint.1
4. Due to the COVID-19 pandemic, the trial date was continued to March 29, 2022,
necessitating an amended scheduling order.
5. After unsuccessful efforts to meet and confer with Defendants regarding a new discovery
order in light of the continued trial date, Plaintiff filed the Motion to Reopen Discovery on
June 18, 2021.
6. On July 28, 2021, over three months after this Court denied Defendants’ Motion to Strike
the First Amended Complaint, Defendants first informed Plaintiffs that Defendants would
be filing a Writ of Mandamus to overturn this Court’s decision. The Writ of Mandamus is
apparently the sole basis for Defendants’ Motion for Continuance.
A. Delaying The Discovery Hearing Until After the Writ of Mandamus is Briefed,
Argued, and Decided Would Prejudice Plaintiffs
7. Trial is set for March 29, 2022. Defendants assert that the First Amended Petition
“completely changes the basis of the case,” which implies that Defendants’ cases theories
have also changed. (Breining Decl. ISO Plaintiffs’ Motion to Reopen Discovery, Exhibit
A, Transcript 5:1-5.) Plaintiffs need time to conduct discovery relating to Defendants’
contentions, defenses, and evidence in light of the purported “complete change.”
Continuing the hearing to some unspecified time after Defendants’ untimely, yet-to-be-
filed Writ Petition has been briefed, argued, and decided destroys Plaintiffs’ ability to
conduct meaningfill discovery aimed at narrowing issues before trial. If the instant motion
Previously filed Breining Decl. ISO Plaintiffs’ Motion to Reopen Discovery, Exhibit B.
1
is granted, either (1) Plaintiffs will have insufficient time to conduct discovery before trial
or (2) trial will once again have to be continued, further delaying justice and finality to the
Harris family. Neither option is in the interest of justice.
Defendants Fail To Establish That Any Decision Regarding the Writ of Mandamus
Would Moot the Motion to Re-Open Discovery
Defendants’ claim is apparently based upon the assertion that Plaintiffs’ Motion to Re-
Open Discovery “may” be moot if Defendants succeed on their to-be—filed Writ. (Def.
Motion, 1]] 1.) However, Defendants fail to establish as much. It is well-established that a
trial court has broad discretion in matters of discovery. Cruz v. Schell (Tex.Ct.App. Aug.
7, 2012, No. 05-01-00565-CV) 2012 Tex. App. LEXIS 6480, at *14 (trial court Within its
discretion to re-open discovery on the remaining cause of action pending in the case after
summary judgment motion). Nothing prevents this Court from re—opening discovery as to
the remaining causes of action to narrow issues and facts prior to trial in the interest of
judicial economy, even if a writ of mandate issues. Nor do Defendants establish that a
successful Writ of Mandamus would necessarily result in dismissal of Plaintiffs’ case.
Accordingly, Defendants have failed to establish the assertion (i.e., that a successful Writ
of Mandamus will moot filrther discovery) upon which their entire Motion for Continuance
is based. Thus, Defendants’ Motion for Continuance should be denied.
No Prejudice Exists to Defendants in Appearing at the Hearing on Plaintiffs’ Motion
to Compel.
Unlike Plaintiffs, who will suffer prejudice if the Discovery hearing is continued,
Defendants do not claim (nor can they) that they will be prejudiced if the Discovery hearing
commences at its scheduled time. Defendants have been granted the statutorily-mandated
time to vigorously oppose the motion. Further, even if Plaintiffs’ Motion is granted, the
only “burden” on Defendants is that they will have to engage in reasonable discovery, an
obligation shared by each and every litigant in a Texas courthouse.
10. In the highly unlikely event that an appellate court later determines that this Court erred in
denying Defendants’ Motion to Strike, Defendants cannot show they will be unduly
prejudiced by having to respond to reasonable discovery requests in the meantime. Every
litigant has an obligation to engage in reasonable discovery, and the off chance that an
appellate court “may” disagree with the trial court at some point in the future is not grounds
for avoiding such discovery.
Defendants Petition for Writ of Mandamus Will Likely Be Denied, As Waited Three
Months to Raise This Issue
11 .Although Defendants have not served Plaintiffs with the yet-to-be-filed Writ, which
purportedly serves as basis for their Motion to Continue, the available procedural facts
alone are sufficient grounds to deny Defendants’ Writ. Although mandamus is a legal
remedy, it is largely controlled by equitable principles, including the concept that equity
aids the diligent and not those who slumber on their rights. Rivercenter Assocs. v. Rivera,
858 S.W.2d 366, 367 (Tex. 1993). A delay of only a few months can result in waiver by
laches. Id. at 366.
12. Defendants waited over three months to challenge this Court’s denial of Defendants’
Motion to Strike. Defendants’ Motion to Continue makes no attempt to explain this
unexcused delay in seeking relief. The fact that Defendants waited to seek relief from this
Court’s denial of Defendants’ Motion to Strike until its last day to oppose Plaintiffs’
Motion to Reopen Discovery shows Defendants’ intent: delay, delay, delay.
. Defendants’ Substantive Objections to Plaintiffs’ Motion to Reopen Discovery
13. Defendants Motion does not argue that they had insufficient time respond to Plaintiffs’
Motion to Reopen Discovery. Rather, Defendants indeed did file a Response. In short,
Defendants’ Response lobs various unfounded accusations at counsel for Plaintiffs based
on statements taken completely out of context. However, it is important to note what
Defendants’ Response does and does not do:
a. does not articulate any undue burden they will face by responding to reasonable
discovery;
b. does not dispute, thus concedes, that filrther discovery will narrow issues at trial;
and
c. does not articulate how allowing further, reasonable discovery would render prior
discovery “moot” (Def. Response, pg. 2).
14. Contrary to Defendants’ contentions, Plaintiffs are not seeking to start discovery over
from scratch. Plaintiffs’ requested targeted discovery will narrow issues prior to trial and
push the parties towards informal resolution. Plaintiff respectfully requests that this
Court allow the requested discovery such that trial can be adjudicated on its merits, the
clear preference in Texas. Holt Atherton Industries, Inc. v. Heine (Tex. 1992) 835 S.W.2d
80, 86.
CONCLUSION
15. It is in the interest of justice to proceed with the hearing as scheduled without delay, and
to permit further discovery. Further discovery will not only allow for a narrowing of issues
at trial and more serious settlement discussions, but is also consistent with the Texas
preference towards adjudication on the merits. HoltAtherton Industries, Inc. v. Heine (Tex.
1992) 835 S.W.2d 80, 86. Plaintiffs respectfully request that this Court deny Defendants’
Motion for Continuance and grant Plaintiffs’ Motion to Reopen Discovery, and for any and
all other relief in law and equity for which Plaintiffs may be entitled.
Respectfully submitted,
/s/ Natalie M Arledge
Michael R. Cowen
Texas Bar No. 00795306
Natalie M. Arledge
Texas Bar No. 24073464
COWEN RODRIGUEZl PEACOCK
|
6243 IH-10 West, Suite 801
San Antonio, Texas 78201
Telephone: (210) 941-1301
Facsimile: (210) 579-8968
E-Mail for Service: efilings@cowenlaw.com
and
Brooks Cutter (admitted pro hac vice)
Matthew Breining (admitted pro hac Vice)
CUTTER LAW, P.C.
401 Watt Avenue
Sacramento, California 95 864
Telephone: (916) 290-9400
Facsimile: (916) 588-9330
E-Mail: boutter@cutter1aw.com
E-Mail: mbreining@cuttterlaw.com
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been delivered, in the
required manner, to all counsel of record in accordance the applicable Rules of Civil Procedure on
July 28, 2021:
Aaron J. Burke Via E—Fz'le
Kathleen M. Cruz
BURKE BOGDANOWICZ PLLC
1201 Elm Street, Suite 4000
Dallas, Texas 75270
Robert J. Bogdanowicz III Via E-Fz'le
Whitney L. Warren
BURKE BOGDANOWICZ PLLC
1201 Elm Street, Suite 4000
Dallas, Texas 75270
/s/ Natalie M. Arledge
Natalie M. Arledge
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.
Michael Cowen
Bar No. 795306
efilings@cmbtrial.com
Envelope ID: 55804980
Status as of 7/29/2021 2:20 PM CST
Associated Case Party: BRANDIE HARRIS, IND
Name BarNumber Email TimestampSubmitted Status
Michael Raphael Cowen 795306 efilings@cowenlaw.com 7/28/2021 9:49:42 PM SENT
Matthew Breining mbreining@cutterlaw.com 7/28/2021 9:49:42 PM SENT
Associated Case Party: SB PREMIUM LLC
Name BarNumber Email TimestampSubmitted Status
Aaron JBurke aaron@burkebog.com 7/28/2021 9:49:42 PM SENT
Kathleen Cruz kcruz@burkebog.com 7/28/2021 9:49:42 PM SENT
Vikki Colvin-Gray vcolvin@burkebog.com 7/28/2021 9:49:42 PM SENT
Deanna Ortega dortega@burkebog.com 7/28/2021 9:49:42 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Tori S. Levine tori.Ievine@wilsonelser.com 7/28/2021 9:49:42 PM SENT
Debbie Liska dliska@cbsattorneys.com 7/28/2021 9:49:42 PM SENT
Andrea Castillo acastiIlo@cbsattorneys.com 7/28/2021 9:49:42 PM SENT
Jean Ann Undenlvood junderwood@cbsattorneys.com 7/28/2021 9:49:42 PM SENT
Audra MDean audra.dean@wilsonelser.com 7/28/2021 9:49:42 PM ERROR
Associated Case Party: WAGES AND WHITE LION INVESTMENTS, LLC.,
Name
Mary Melle
Wendy Harpel
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.
Michael Cowen
Bar No. 795306
efilings@cmbtrial.com
Envelope ID: 55804980
Status as of 7/29/2021 2:20 PM CST
Associated Case Party: WAGES AND WHITE LION INVESTMENTS, LLC.,
Whitney L.Warren wwarren@burkebog.com 7/28/2021 9:49:42 PM SENT
Robert JBogdanowicz rob@burkebog.com 7/28/2021 9:49:42 PM SENT
Preview
FILED 7/28/2021 9:49 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Terri Kilgore DEPUTY CAUSE NO. DC-19-00359 BRANDIE HARRIS, INDIVIDUALLY IN THE DISTRICT COURT AND AS HEIR AND REPRESENTATIVE OF THE ESTATE OF NEIL HARRIS AND AS NEXT FRIEND OF MINORS, OH AH AND BH VS. 68TH JUDICIAL DISTRICT SB PREMIUM, LLC D/B/A SUICIDE BUNNY, TIFFANY RESHAM, LARRY SCOTT GRESHAM, SB PRODUCTS, SUICIDE BUNNY, WAGES AND WHITE LION INVESTMENTS, LLC D/B/A TRITON DISTRIBUTION, WHITE LION INVESTMENTS, LLC D/B/A TRITON DISTRIBUTION, SCS VAPE, LLC, VAPEWILD WHOLESALE, INC. F/K/A WOLEPACK WHOLESALE, INC. DALLAS COUNTY, TEXAS PLAINTIFF’S RESPONSE TO DEFENDANTS’ JOINT MOTION FOR CONTINUANCE OF HEARING TO RE-OPEN DISCOVERY COMES NOW, Plaintiff Brandie Harris, in the above-styled case and files this Response to Defendants’ Joint Motion for Continuance of Hearing to Re-Open Discovery. In support thereof, Plaintiff shows the Court as follows: SUMMARY OF THE ARGUMENT l. Defendants’ Motion for Continuance asks this Court to abstain from resolving the instant discovery dispute, and instead wait to set the matter for hearing until after Defendants’ Writ of Mandamus has been briefed, argued, and decided. This is a clear attempt to fiIrther delay justice and finality to the Harris family, Who lost their husband and father over three years ago. 2. Defendants’ Motion is devoid of any legal authority to support its request. Further, Defendants’ Motion Wholly fails to articulate hOW it Will be prejudiced if the Motion to Reopen is heard as scheduled. Defendants fail to establish that any resolution of the Writ of Mandamus would render the Motion to Reopen moot, nor do Defendants establish that participating in reasonable discovery would be an unfair burden. Accordingly, the Court should deny Defendants’ Motion for Continuance. BACKGROUND 3. On April 26, 2021, this Court denied Defendants’ Motion to Strike the First Amended Complaint.1 4. Due to the COVID-19 pandemic, the trial date was continued to March 29, 2022, necessitating an amended scheduling order. 5. After unsuccessful efforts to meet and confer with Defendants regarding a new discovery order in light of the continued trial date, Plaintiff filed the Motion to Reopen Discovery on June 18, 2021. 6. On July 28, 2021, over three months after this Court denied Defendants’ Motion to Strike the First Amended Complaint, Defendants first informed Plaintiffs that Defendants would be filing a Writ of Mandamus to overturn this Court’s decision. The Writ of Mandamus is apparently the sole basis for Defendants’ Motion for Continuance. A. Delaying The Discovery Hearing Until After the Writ of Mandamus is Briefed, Argued, and Decided Would Prejudice Plaintiffs 7. Trial is set for March 29, 2022. Defendants assert that the First Amended Petition “completely changes the basis of the case,” which implies that Defendants’ cases theories have also changed. (Breining Decl. ISO Plaintiffs’ Motion to Reopen Discovery, Exhibit A, Transcript 5:1-5.) Plaintiffs need time to conduct discovery relating to Defendants’ contentions, defenses, and evidence in light of the purported “complete change.” Continuing the hearing to some unspecified time after Defendants’ untimely, yet-to-be- filed Writ Petition has been briefed, argued, and decided destroys Plaintiffs’ ability to conduct meaningfill discovery aimed at narrowing issues before trial. If the instant motion Previously filed Breining Decl. ISO Plaintiffs’ Motion to Reopen Discovery, Exhibit B. 1 is granted, either (1) Plaintiffs will have insufficient time to conduct discovery before trial or (2) trial will once again have to be continued, further delaying justice and finality to the Harris family. Neither option is in the interest of justice. Defendants Fail To Establish That Any Decision Regarding the Writ of Mandamus Would Moot the Motion to Re-Open Discovery Defendants’ claim is apparently based upon the assertion that Plaintiffs’ Motion to Re- Open Discovery “may” be moot if Defendants succeed on their to-be—filed Writ. (Def. Motion, 1]] 1.) However, Defendants fail to establish as much. It is well-established that a trial court has broad discretion in matters of discovery. Cruz v. Schell (Tex.Ct.App. Aug. 7, 2012, No. 05-01-00565-CV) 2012 Tex. App. LEXIS 6480, at *14 (trial court Within its discretion to re-open discovery on the remaining cause of action pending in the case after summary judgment motion). Nothing prevents this Court from re—opening discovery as to the remaining causes of action to narrow issues and facts prior to trial in the interest of judicial economy, even if a writ of mandate issues. Nor do Defendants establish that a successful Writ of Mandamus would necessarily result in dismissal of Plaintiffs’ case. Accordingly, Defendants have failed to establish the assertion (i.e., that a successful Writ of Mandamus will moot filrther discovery) upon which their entire Motion for Continuance is based. Thus, Defendants’ Motion for Continuance should be denied. No Prejudice Exists to Defendants in Appearing at the Hearing on Plaintiffs’ Motion to Compel. Unlike Plaintiffs, who will suffer prejudice if the Discovery hearing is continued, Defendants do not claim (nor can they) that they will be prejudiced if the Discovery hearing commences at its scheduled time. Defendants have been granted the statutorily-mandated time to vigorously oppose the motion. Further, even if Plaintiffs’ Motion is granted, the only “burden” on Defendants is that they will have to engage in reasonable discovery, an obligation shared by each and every litigant in a Texas courthouse. 10. In the highly unlikely event that an appellate court later determines that this Court erred in denying Defendants’ Motion to Strike, Defendants cannot show they will be unduly prejudiced by having to respond to reasonable discovery requests in the meantime. Every litigant has an obligation to engage in reasonable discovery, and the off chance that an appellate court “may” disagree with the trial court at some point in the future is not grounds for avoiding such discovery. Defendants Petition for Writ of Mandamus Will Likely Be Denied, As Waited Three Months to Raise This Issue 11 .Although Defendants have not served Plaintiffs with the yet-to-be-filed Writ, which purportedly serves as basis for their Motion to Continue, the available procedural facts alone are sufficient grounds to deny Defendants’ Writ. Although mandamus is a legal remedy, it is largely controlled by equitable principles, including the concept that equity aids the diligent and not those who slumber on their rights. Rivercenter Assocs. v. Rivera, 858 S.W.2d 366, 367 (Tex. 1993). A delay of only a few months can result in waiver by laches. Id. at 366. 12. Defendants waited over three months to challenge this Court’s denial of Defendants’ Motion to Strike. Defendants’ Motion to Continue makes no attempt to explain this unexcused delay in seeking relief. The fact that Defendants waited to seek relief from this Court’s denial of Defendants’ Motion to Strike until its last day to oppose Plaintiffs’ Motion to Reopen Discovery shows Defendants’ intent: delay, delay, delay. . Defendants’ Substantive Objections to Plaintiffs’ Motion to Reopen Discovery 13. Defendants Motion does not argue that they had insufficient time respond to Plaintiffs’ Motion to Reopen Discovery. Rather, Defendants indeed did file a Response. In short, Defendants’ Response lobs various unfounded accusations at counsel for Plaintiffs based on statements taken completely out of context. However, it is important to note what Defendants’ Response does and does not do: a. does not articulate any undue burden they will face by responding to reasonable discovery; b. does not dispute, thus concedes, that filrther discovery will narrow issues at trial; and c. does not articulate how allowing further, reasonable discovery would render prior discovery “moot” (Def. Response, pg. 2). 14. Contrary to Defendants’ contentions, Plaintiffs are not seeking to start discovery over from scratch. Plaintiffs’ requested targeted discovery will narrow issues prior to trial and push the parties towards informal resolution. Plaintiff respectfully requests that this Court allow the requested discovery such that trial can be adjudicated on its merits, the clear preference in Texas. Holt Atherton Industries, Inc. v. Heine (Tex. 1992) 835 S.W.2d 80, 86. CONCLUSION 15. It is in the interest of justice to proceed with the hearing as scheduled without delay, and to permit further discovery. Further discovery will not only allow for a narrowing of issues at trial and more serious settlement discussions, but is also consistent with the Texas preference towards adjudication on the merits. HoltAtherton Industries, Inc. v. Heine (Tex. 1992) 835 S.W.2d 80, 86. Plaintiffs respectfully request that this Court deny Defendants’ Motion for Continuance and grant Plaintiffs’ Motion to Reopen Discovery, and for any and all other relief in law and equity for which Plaintiffs may be entitled. Respectfully submitted, /s/ Natalie M Arledge Michael R. Cowen Texas Bar No. 00795306 Natalie M. Arledge Texas Bar No. 24073464 COWEN RODRIGUEZl PEACOCK | 6243 IH-10 West, Suite 801 San Antonio, Texas 78201 Telephone: (210) 941-1301 Facsimile: (210) 579-8968 E-Mail for Service: efilings@cowenlaw.com and Brooks Cutter (admitted pro hac vice) Matthew Breining (admitted pro hac Vice) CUTTER LAW, P.C. 401 Watt Avenue Sacramento, California 95 864 Telephone: (916) 290-9400 Facsimile: (916) 588-9330 E-Mail: boutter@cutter1aw.com E-Mail: mbreining@cuttterlaw.com CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been delivered, in the required manner, to all counsel of record in accordance the applicable Rules of Civil Procedure on July 28, 2021: Aaron J. Burke Via E—Fz'le Kathleen M. Cruz BURKE BOGDANOWICZ PLLC 1201 Elm Street, Suite 4000 Dallas, Texas 75270 Robert J. Bogdanowicz III Via E-Fz'le Whitney L. Warren BURKE BOGDANOWICZ PLLC 1201 Elm Street, Suite 4000 Dallas, Texas 75270 /s/ Natalie M. Arledge Natalie M. Arledge 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. Michael Cowen Bar No. 795306 efilings@cmbtrial.com Envelope ID: 55804980 Status as of 7/29/2021 2:20 PM CST Associated Case Party: BRANDIE HARRIS, IND Name BarNumber Email TimestampSubmitted Status Michael Raphael Cowen 795306 efilings@cowenlaw.com 7/28/2021 9:49:42 PM SENT Matthew Breining mbreining@cutterlaw.com 7/28/2021 9:49:42 PM SENT Associated Case Party: SB PREMIUM LLC Name BarNumber Email TimestampSubmitted Status Aaron JBurke aaron@burkebog.com 7/28/2021 9:49:42 PM SENT Kathleen Cruz kcruz@burkebog.com 7/28/2021 9:49:42 PM SENT Vikki Colvin-Gray vcolvin@burkebog.com 7/28/2021 9:49:42 PM SENT Deanna Ortega dortega@burkebog.com 7/28/2021 9:49:42 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Tori S. Levine tori.Ievine@wilsonelser.com 7/28/2021 9:49:42 PM SENT Debbie Liska dliska@cbsattorneys.com 7/28/2021 9:49:42 PM SENT Andrea Castillo acastiIlo@cbsattorneys.com 7/28/2021 9:49:42 PM SENT Jean Ann Undenlvood junderwood@cbsattorneys.com 7/28/2021 9:49:42 PM SENT Audra MDean audra.dean@wilsonelser.com 7/28/2021 9:49:42 PM ERROR Associated Case Party: WAGES AND WHITE LION INVESTMENTS, LLC., Name Mary Melle Wendy Harpel 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. Michael Cowen Bar No. 795306 efilings@cmbtrial.com Envelope ID: 55804980 Status as of 7/29/2021 2:20 PM CST Associated Case Party: WAGES AND WHITE LION INVESTMENTS, LLC., Whitney L.Warren wwarren@burkebog.com 7/28/2021 9:49:42 PM SENT Robert JBogdanowicz rob@burkebog.com 7/28/2021 9:49:42 PM SENT