Motion to Augment (name extension) in Robert L Moody, Jr. vs. Greer, Herz, & Adams, LLP, Et Al| Trellis.Law

On October 20, 2020 a Appellate Materials was filed involving a dispute between Moody, Robert L, Jr., and Herz, Irwin "Buddy", Three R Trusts, for Injury/Damage - Other in the District Court of Galveston County.

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SUPPLEMENTAL CLERK’S RECORD

Appellate Court Case Number 01‐22‐00202‐CV

Volume ____1_______ of ____1_______

Trial Court Cause No. 20‐CV‐1564

In the Court 122nd District Court

of Galveston County, Texas

Honorable John Ellisor Judge Presiding

_________________________________________________________________

Robert L Moody, Jr. vs. Greer, Herz, & Adams, LLP, Et Al

_________________________________________________________________

Appealed to the Court of Appeals for the First District of Texas, at, Houston, Texas

Attorney for Appellants(s): Anthony G Buzbee

Address: The Buzbee Law Firm

JP Morgan Chase Tower

600 Travis, Suite 7300

Houston, TX 77002

Telephone Number: 713‐223‐5393

Fax Number: 713‐223‐5909

E‐Mail Address: tbuzbee@txattorneys.com

State Bar 0f Texas Number: 24001820

Name Of Appellant/s: Robert L Moody, Jr.

Name of clerk preparing the clerk’s record: John D. Kinard, District Clerk of Galveston County, Texas

By /s/ : Shailja Dixit

1
Supplemental Clerk’s Record

Case Number 20‐CV‐1564 ‐ 122nd District Court

Robert L Moody, Jr. vs. Greer, Herz, & Adams, LLP, Et Al

Date Filed and Document Name Page#

2022‐11‐23_Title 1

2022‐11‐23_Index 2

2022‐11‐23_Caption 3

2020-10-20_Motion to Transfer Venue- Irwin Herz, Trustee of the Three R Trust's 4

2022-11-25_Case Summary 534

2022-11-28_Cost Bill 553

2022-11-28_Clerk’s Certificate 556

2
Supplemental Clerk’s Record

Appeal Caption

The State of Texas
County of Galveston

In 122nd District Court at Galveston, Texas, within and for the County of Galveston, before the
Honorable John Ellisor, Judge thereof Presiding, the following case came on for trial, to-wit:

CASE NUMBER 20-CV-1564

Robert L Moody, Jr. vs. Greer, Herz, & Adams, LLP, Et Al

3
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Distn'ct Clerk
Clerk Harris
Envelope
Harris County
County
Envelope No. 44448162
No. 44448162
By:
By: Lewis
Lewis John-Miller
John-Miller

Cause No. 2020-31023
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Cause No. 2020-3 1023
Filed:
Filed: 7/13/20209:10
7/13/2020 9:1 o AM

ROBERT L.
L. MOODY, JR.
JR. §§ 1N THE DISTRICT COMQB k
§§ gfé’gcirh'cﬂﬁo
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§§ DC;
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v. §§ GAL l,
20
. 2020
§§ HARRIS C0 fﬁ‘xmw
§§ y'
TE’MS
GREER, HERZ, & ADAMS
HERz, & §§
LLP “BUDDY” HERZ
LLP,, IRWIN "BUDDY" HERz,, §§
JR.,
IR, and ROSS RANKIN §§
MOODY. §§ 55TH JUDICIAL DISTRICT

IRWIN HERZ, TRUSTEE OF THE THREE R TRUSTS'S,
TRUSTS’S.
MOTION TO TRANSFER VENUE TO GALVESTON COUNTY, AND, SUBJECT TO
THAT MOTION, HIS ORIGINAL ANSWER AND AFFIRMATIVE DEFENSES

Defendant Irwin
Irwin "Buddy" Herz, Jr.
“Buddy” Herz, Jr. ("Defendant
(“Defendant Herz" or "Trustee
Hérz” or “Trustee Herz"),
Herz”), individually
individually

and as
as Trustee of the
the Three R Trusts,
Trusts, hereby
hereby files
ﬁles this
this Motion to
t0 Transfer
Transfer Venue to
to Galveston
Galveston

County and,
and, subject
subject to without waiver of that
to and without that transfer
transfer motion,
motion, his
his Original
Original Answer and
and

Affirmative
Afﬁrmative Defenses to
to Robert
Robert Moody, Jf.'
Jr.’ss Original
Original Petition,
Petition, and
and in
in support
support thereof
thereof would

respectfully
respectfully show the
the Court as
as follows:
follows:

MOTION TO TRANSFER VENUE

Trust Code mandates
The Texas Trust mandates that venue in
that venue in this case must
this case must be
be where the Trusts are
the Trusts are

administered or
administered or where the
the Trustee
Trustee resides.
resides. In
In both
both cases,
cases, that
that is Galveston County.
is Galveston County. Even if
if that
that

not
were not so, however, venue in
so, in Ham's
Harris County
County would be
be improper.
improper. None of
of the
the parties
parties live
live in
in .

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31
Harris County.
Harris County. Plaintiff Robert
The Plaintiff Robert Moody Jr.
Jf. (“Robert
("Robert Jr.”
Jf." or
or Plaintiff),
Plaintiff), Defendant Greer,
Greer, Herz
of W
1
& L.L.P. (“GHA”),
Adams L.L.P. ("GHA"), and Defendant Trustee
Trustee Irwin
Irwin “Buddy”
"Buddy" Herz,
Herz, Jr.
Jr. (“Trustee
("Trustee Herz”)
Herz") all
all 5775:"

Page

live in or
in or their principal
principal ofﬁces
offices Galveston County,
in Galveston County, and
and Defendant
Defendant Ross
Ross Rankin
Rankin Moody
-

live have their in ,.
b

yr
g;
91271430

("Ross") lives
(“Ross”) lives in
in Travis
Travis County.
County. did aa substantial
Nor did substantial part of the
part of the alleged
alleged actions
actions that give rise
that give to
rise to
/"‘fj

q
Number:
his litigation
his litigation occur
occur in
in Harris
Harris County.
County. situs of
The situs of administration for the
administration for the Trusts at is‘sue’in
Trusts at issue in this
this

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litigation is in Galveston County,
litigation is in Galveston County, the
the entities
entities about
about which the
the Plaintiff
Plaintiff complains
complains in his Petition,
in his Petition,
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Document

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2O-CV-1564
20-cv-1564
U DCMOTRAN
DCMOTRAN
o 1 Motion
Motion to Transfer
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2101833
to Transfer

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including Moody National Bank, the Moody Foundation, American National Insurance Company,

and others, are located in either Galveston County, or in the case of National Western Life Group,

Inc., in Travis County. None of the beneficiaries of the Trusts live in Harris County. There is no

reason and no basis in Texas law for this case to be brought in Harris County. As such, Defendants

respectfully request that this Court transfer this action to Galveston County.

FACTUAL BACKGROUND

A. Introduction

This is the fourth in a series of lawsuits filed by Plaintiff Robert Jr. as part of an "outright

war" being waged by him against his youngest brother, Defendant Ross Moody, and various

entities and business interests of their father, Robert Moody, Sr. ("Robert Sr."). The first was a

derivative suit brought by Robert Jf. against his brother, Defendant Ross Moody, and the publicly-

traded insurance company for which Ross is the Chainnan, President and CEO, National Western

Life Group, Inc. ("National Western"), as well as certain other directors of National Western. l

That suit was brought in Galveston County, Texas. It was dismissed and the district court assessed

$1.3 million in attorneys' fees against Robert Jr. Ex. 1 at xv. The second was a Sarbanes-Oxley

complaint filed against National Western with the Department of Labor, which was also dismissed.

Ex. 2. And the third was a suit brought against another publicly-traded insurance company,

American National Insurance Company ("American National"), for which Defendant Ross is the

non-officer Chairman, and for which Trustee Herz is a director. That suit was also brought in

Galveston, this time in federal court. It too was recently dismissed. Ex. 3. 2 Now, Robert Jf. has

initiated this fourth suit of his "outright war that could jeopardize what [their] father has built"-

1 See Rohert J" Afood"v, .Jr., {)erivative~v 011 Rehal/o/:Vat 'I IF. Uje Ins. Co. and Natl. W. !,ije Grp., Inc. l'. Ros,\' Rankin
....c l\Jaod"v et al.. No. 17 -CV-1196 (Tex. Dist.-Galveston [122 nd Dist. C1.] [filed Sept. 28. 20 l7]) .
11)
2 See A1aad"v v. Am. /v'at'lins. Ca., 3: 19-CV-00206, 2020 WL 3128259. at *1 (S.D. Tex. June 12,2020).
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this time trying a new forum-and has now included allegations against Trustee Herz, the Trustee

of the Three R Trusts for the past 49 years. Ex. 4 at RRMOOOlll; Ex. 5 at 1.

The crux of Robert Jr.' s grievances both in those prior lawsuits and in this one-made plain

on the face of the Petition-is that he is upset he has not been elected to the boards of, and has

been denied monetary and nonmonetary benefits from, various regulated financial institutions and

charitable foundations that were created by Moody family members in past decades-many of

which have little or nothing to do with the Three R Trusts. Compare Ex. 5 at 1-2 with Petition at

26-31. But certainly, neither Trustee Herz nor Ross Moody nor Defendant Greer, Herz & Adams

L.L.P-to the extent that any of them had the ability to even control such things-had any sort of

fiduciary obligation to ensure that Robert Jr. sat on a sufficient number of boards and/or received

a sufficient amount of monetary and non-monetary perks from these various institutions and

foundati ons.

B. The Three R Trusts

Robert Sr. established the Three R Trusts in Galveston in 1960 as irrevocable trusts to

benefit his children and their descendants. They have been amended a few times during their

existence, each time in Galveston County. E.g., Ex. 6 ("Trust Agreement") at 1, 9, 15, 20. There

are four beneficiaries of the Three R Trusts-Plaintiff Robert Jr., Defendant Ross, and their

siblings, non-parties Frances Moody-Dahlberg ("Francie") and Russell Moody. Plaintiff Robert

Jr. is a resident of Galveston County, Defendant Ross is a resident of Travis County, Francie is a

resident of Dallas, and Russell lives in League City, in Galveston County. Ex. 7 ("Declaration of

Irwin Herz Jr.") at ~ 16. The Settlor of the Trusts, Robert Sr., remains in Galveston and his interests

are managed by a Power of Attorney that is administered in Galveston. Ex. 7 at ~ 14 .

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Herz became Trustee of the Three R Trusts in 1971 (Ex. 7 at ~ 11), when the assets were

worth approximately $4 million. The Three R Trusts are currently worth well in excess of $400

million. The assets of the Three R Trusts include a majority interest in Moody Bancshares, Inc.-

which owns the majority of the stock in Moody National Bank-and the Regent Care entities,

which operate nursing homes. Both Moody National Bank and the Regent Care companies are

headquartered in Galveston County. Ex. 7 at ~ 18. Robert Jr.' s own office is located at the Moody

National Bank Tower in Galveston County. Ex. 7 at ~ 17. On the day before this lawsuit was

filed, in a conversation that took place in Galveston County, Plaintiff Robert Jr. told the President

of Regent Care and the President of Moody National Bank that each was doing an excellent job

and was to be highly commended and that the companies' financial conditions were outstanding.

Ex. 7 ~ 19. The Three R Trusts also own American National and National Western stock,

although in amounts that are negligible in relation to the total shares outstanding in those

compames. National Western is headquartered in Travis County but has offices in Galveston

County, while American National is headquartered in Galveston County. Ex. 7 at ~~ 33-34.

c. Trustee Irwin Herz

Trustee Herz has not served as Trustee of the Three R Trusts for the past 49-years for

financial gain. He does so as part of a commitment to his longtime personal friend, the Settlor of

the Trusts, Robert Sr., who was a groomsman at his wedding over 50 years ago. His fee for acting

as Trustee is only $200 per month. Ex. 7 at ~ 12. And Trustee Herz still lives in the same Galveston

home he purchased in 1979 at 2909 Dominique, Galveston, TX 77551 (the "Galveston Home").

Ex. 7 at ~ 2. This is the address that appears on his driver's license, where he is registered to vote,

and where his automobile is registered. Ex. 7 at ~ 3. It is also where Trustee Herz takes his

homestead exemption and his over-65 exemption. Ex. 7 at ~ 3. Plaintiff Robert Jr. is aware that
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Trustee Herz lives in Galveston, not Houston-because that is where he served him with this

lawsuit. In all respects, Trustee Herz both lives in, and administers the Trusts from, Galveston.

Ex. 7 at ~~ 1-4 ~ 10 ~ 13.

Historically, when Trustee Herz has met with Robert Sr. to discuss the Trusts, those

meetings have also taken place in Galveston. Though the routine has been paused for a few months

due to the recent pandemic, Trustee Herz has traditionally had lunch with Robert Sr. during the

work week on an almost daily basis at the American National executive dining room, also in

Galveston. Ex. 7 at ~ 15. Similarly, when Trustee Herz has phone calls or meetings with

beneficiaries of the Trusts, he typically does so from Galveston County. Ex. 7 at ~~ 13,21.

In 2001 Trustee Herz bought a second home, a one-and-a-halfbedroom condominium, in

Harris County, to have a place closer to his grandchildren (the "Houston Condo"). Ex. 7 at ~ 5.

Trustee Herz typically spends no more than one or two weekends a month at the Houston Condo.

Ex. 7 at ~ 7. He almost never spends weeknights at the Houston Condo-as little as a few times a

year. Ex. 7 at ~ 8. And he has never slept there for any extended period of time save for a few

month period in 2008 after Hurricane Ike hit Galveston and made living in his permanent residence

on the island impossible. Ex. 7 at ~ 9. Rather, Trustee Herz has always considered Galveston

County his permanent home and has never had any intention of residing in Harris County. Ex. 7

at ~~ 1, 10.

D. Greer, Herz, & Adams L.L.P.

Trustee Herz, through a professional corporation, is a partner in the law firm of Defendant

Greer, Herz & Adams, L.L.P ("GHA"). Ex. 7 at ~ 24. Trustee Herz has been associated with that

law firm for decades. Id. Though its name and circumstances have changed over the years, GHA

or its predecessor firms have provided legal services to various entities founded by Moody family
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members for decades. Ex. 7 at ~ 25. Before 1978, a predecessor firm to GHA in fact served as in-

house counsel at American National in addition to operating an outside practice for other clients

and businesses, including various Moody entities. Ex. 7 at ~ 26. In 1978, those lawyers moved the

firm outside of American National, but continued to provide legal services to American National

and other Moody and non-Moody entities. Ex. 7 at ~ 27. That law firm has changed names over

the years due to the retirement of various partners, but is now called GHA. Id In total, GHA or

its predecessors have provided legal services to American National and the Moody National Bank,

from its Galveston office, for around 90 years, and to the Moody Foundation for over 70 years.

Ex. 7 at ~ 31.

The Trusts pay for legal services performed on its behalf by GHA and other law firms, as

is expressly permitted by the Trust Agreement. E.g., Ex. 4 at p.51 (Article II(d)-(e)). GHA

typically charges $200 per hour for its attorneys' services to the Trusts and for companies

controlled by the Trusts, and between $300 and $450 per hour to other entities, such as American

National. Ex. 7 at ~ 30. GHA has two offices-its principal office in Galveston, and a second

office in League City-both of which are in Galveston County. Ex. 7 at ~ 28. Trustee Herz's sole

office, from which he performs much of his work for the Trusts, is at GHA's office in Galveston.

Ex. 7 at ~ 29.

E. Administration of the Three R Trusts

For the past few years, the trust department of the Moody National Bank has assisted in

keeping the accounts and the books of the Trusts. The trust officers who do this are located at

Moody National Bank's headquarters in Galveston County. Ex. 7 at ~ 20. Before that, personnel

in Robert Sr.' s office, at Moody National Bank Tower, also in Galveston, assisted with the

bookkeeping for the Trusts. Id.
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Over these past few years, Trustee Herz has held meetings every one-to-two months with

the four beneficiaries of the Trusts, the Moody Bank president, the Moody Bank Senior Trust

officer, and other Bank employees present. These meetings take place at the ground floor

conference room of the Moody National Bank in Galveston. Ex. 7 at ~ 21. At these meetings,

issues relating to Three R Trusts' investments and administration are disclosed in detail. ld. The

beneficiaries have also received financial statements and tax returns from the Trusts for at least the

past twenty years, prepared by an accounting firm in Galveston. Ex. 7 at ~ 22.

F. Other Moody Entities

Although the Petition mentions the Moody Foundation 14 times and the Moody

Endowment 9 times, the Three R Trusts have little to do with either, which are independent

charitable organizations and not a part of the corpus of the Three R Trusts. The Moody Foundation

was established by W.L. Moody, lr. and Libbie Shearn Moody (Robert Sr.'s grandparents) in 1942

as a charitable trust "for the furtherance of 'religious, charitable, scientific and educational uses'

within the State of Texas." Moody v. Haas, 493 S.W.2d 555,556 (Tex. App.-Houston [14 th Dist.]

1973). Since its inception, the Foundation has made over $1.9 billion in contributions throughout

the state of Texas. The Moody Endowment was formed by Robert Sr. in 1985 as a non-profit

organization providing financial support to the Transitional Learning Center (located in Galveston

since the early 1980s and also known as the Moody Neurorehabilitation Institute), which provides

survivors of brain injury with rehabilitation services.

Even if the Moody Foundation or the Moody Endowment-or Robert lr.'s entitlement to

board seats or board fees on or from them-had some bearing on this case, however, both

organizations, like nearly all the other entities and individuals named in the Petition, are not located

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in Harris County. Both are headquartered in Galveston County, although the Moody Foundation

also has a small office in Dallas. Ex. 7 at ~ 32.

Robert Jr. 's attempt to forum-shop this lawsuit to a new venue-Harris County-because

his prior complaints about his position with respect to Moody-related financial institutions, two of

which are publicly traded, and charitable foundations, achieved no success in Galveston, in either

state court or federal court, should not be allowed. His serial litigation against Defendant Ross

and the Moody family entities-now including Trustee Herz, who has served loyally as Trustee

for almost 50 years-constitutes an abuse of the legal system, and so too would it be to allow this

case, where none of the relevant Trusts, individuals, entities, or events are located in Harris County,

to proceed here.

SPECIFIC DENIAL OF VENUE PLAINTIFF'S ALLEGATIONS

Trustee Herz specifically denies each and every allegation within the Petition that could be

construed as a venue allegation, if any. Trustee Herz specifically denies that he resides in Harris

County. Trustee Herz specifically denies that Harris County is the county in which all or a

substantial part of the events or omissions giving rise to the claims occurred. Trustee Herz is a

resident of Galveston County. The Trusts are administered in Galveston County. The complaints

made by Robert Jr.-regarding the perceived denial of various perks from publicly traded and

regulated financial institutions and charitable boards, the alleged conflicts of interest in the

performance of legal services, and the other alleged breaches of fiduciary duty-to the extent they

happened at all, which Trustee Herz denies, could only have happened in Galveston County (or,

for National Western, in Travis County), where the relevant parties, companies, and foundations,

are almost entirely located.

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ARGUMENT & AUTHORITIES

Plaintiff Robert lr. bears the burden of demonstrating that venue in Harris County is

appropriate in this case. "The plaintiff has the first choice to fix venue in a proper county by

bringing the action in the county of his choice. If a defendant obj ects to the plaintiff s choice

through a timely motion to transfer venue, the plaintiff must prove that venue is proper in the

county of suit." Cantil v. Howard S. Grossman, P.A., 251 S.W.3d 731, 735 (Tex. App.-Houston

[14th Dist.] 2008, no pet.). He cannot do so because venue is improper in Harris County.

Plaintiff argues that venue is appropriate in Harris County on two grounds-(l) that

Trustee Herz is a resident of Harris County and (2) all or a substantial amount of the events at issue

took place in Harris County. See Petition at 5. Defendants specifically deny both of these

assertions. First, venue in this case is mandatory where Trustee Herz resides under Section

115.002 of the Texas Trust Code. See Tex. Prop. Code § 115.002. While Trustee Herz owns a

one-and-a-half-bedroom condominium in Houston, Texas where he might spend a few days a

month visiting his grandkids, his residence, is-and has been nearly his entire life-Galveston,

County. Ex. 7 at ~~ 1-10. Second, because venue is mandatory in Trustee Herz's county of

residence, whether or not a "substantial amount of the events" took place in Harris County is

irrelevant. Even if it were relevant, however, it is not true. The Plaintiff, the Defendants, the

Trusts, the non-party beneficiaries, the Settlor, and the financial institutions and various charitable

organizations complained of in the Petition are almost entirely located in Galveston County (or,

alternatively, in Travis County), not in Harris County.
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~ I. The Trust Code Provides for Mandatory Venue of Galveston County
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Venue in this action is controlled by Section 115.002 of the Texas Trust Code. See Tex.
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Texas Civil Practice and Remedies Code, that provision controls over the general venue rules. Tex.

Civ. Prac. & Rem. Code Ann. § lS.016 ("An action governed by any other statute prescribing

mandatory venue shall be brought in the county required by that statute. ").

Section 11S.002 provides that the "venue of an action under Section 11S.001"-meaning

any action "by or against a trustee and all proceedings concerning trusts"-"shall be brought in

the county in which: (1) the trustee resides or has resided at any time during the four-year period

preceding the date the action is filed~ or (2) the situs of administration of the trust is maintained or

has been maintained at any time during the four-year period preceding the date the action is filed."

Tex. Prop. Code. § 11S.002(b)(l)-(2). Section 11S.002 uses the language shall, and therefore

provides for mandatory, not permissive, venue. III re Wheeler, 441 S.W.3d 430,434 (Tex. App.-

Waco 2014, no pet.) ("Section 11S.002 of the Texas Property Code is a mandatory-venue

provision."); see also III reJ.P. Morgan Chase Bank, N.A., 373 S.W.3d 610,614 (Tex. App.-San

Antonio 2012, no pet.).

This action is both against a Trustee and concerns trusts, the Three R Trusts. See e.g.,

Petition at 4. Therefore venue is only proper in a county where the trustee resides or has resided

in the previous four years and/or where the situs of administration of the trust is maintained or has

been maintained during the previous four years. In both cases, the only appropriate venue for this

case is Galveston County. Because there is mandatory venue in this case, a failure to transfer this
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96 S.W.3d 673, 677 (Tex. App.-Austin 2003, no pet.).

A. It is Undisputed that the Situs of the Trusts is Galveston County

First, it cannot be disputed that the situs of the Three R Trusts is and always has been

Galveston County. The "situs of administration" is the location where "the trustee maintains the
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office that is responsible for dealing with the settlor and beneficiaries of the trust." Tex. Prop.

§ 115.002(£)(3). Trustee Herz has been the sole trustee of the Trusts since 1971, for nearly 50

years. Ex. 7 ~ 11. Trustee Herz's office is located in Galveston County. Ex. 7 ~ 4. The trust

department of the Moody National Bank, which assists with the bookkeeping of the Trusts and

holds the accounts of the Trusts, is also located in Galveston County. Ex. 7 ~~ 20-21. Trustee

Herz deals with the beneficiaries of the Trust-who live in Travis County (Ross), Galveston

County (Robert Jr., Russell), and Dallas County (Francie)-from Galveston County. Ex. 7 at

~~ 16~ 21. In fact, Plaintiff Robert Jr.'s own home and office are in Galveston County. Petition at

4, 23 (complaining about an alleged attempt to "evict" Robert Jr. "from his office that he has had

for more than thirty three years" at Moody National Bank).

Trustee Herz's dealings with the Settlor of the Trust, Robert Moody, Sr. have also largely

taken place in Galveston. Though Robert Moody Sr. has been ill for the last few years, before the

recent pandemic, Trustee Herz, as his longtime personal friend, had continued to have lunch with

him during the work week on a daily basis at the American National executive dining room in

Galveston. Ex. 7 ~~ 14-15. These facts are conclusive in terms of determining the situs of the

administration of the trust. See In re Green, 527 S.W.3d 277, 280 (Tex. App.-EI Paso 2016, no

pet.) (trial court abused its discretion by denying motion to transfer venue to county where

"business office" where trustee "dealt with the trust beneficiaries primarily" was located). Finally,

the terms of the Trust Agreement, which have been amended various times, have always been so

amended in Galveston County. See e.g.. Ex. 6 at pp. 1, 9, 15, 20. In his Petition, Plaintiff Robert

Jr. does not (and cannot) deny that the situs of administration for the Trusts is in Galveston.

14
B. Trustee Herz Resides in Galveston County

Second, Trustee Herz resides in Galveston County, not in Harris County. Plaintiff Robert

Jr. alleges that Trustee Herz has two residences-one in Galveston County and a second residence

in Harris County. See Petition at 5, n.4. It is true that Trustee Herz owns propert

Case Info

Judge

Jones, Jeth Track Judge’s New Case

Case No.

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Document Filed Date

November 28, 2022

Case Filing Date

October 20, 2020

County

Parties

Anthony G Buzbee Attorney for the Plaintiff
Herz, Irwin "Buddy" Appellee
Herz, Irwin "Buddy" Defendant
Herz, Irwin "Buddy" Trustee
Moody, Robert L, Jr. Appellant
Moody, Robert L, Jr. Plaintiff
Robin C. Gibbs Attorney
Robin C. Gibbs Attorney for the Appellee
Robin C. Gibbs Attorney for the Defendant
Three R Trusts Defendant
Ross MacDonald Attorney
David Bergen Attorneys for Plaintiffs
Robert Daniel Attorneys for Defendants
Hannah Roblyer Attorneys for Defendants
David Beck Attorneys for Defendants
Allison Miller Attorneys for Defendants
Samuel Cruse Attorneys for Defendants
Angus Dodson Attorney
Harry Reasoner Attorney
Stacey Vu Attorneys for Defendants
Brittany Ifejika Attorneys for Plaintiffs
Conor McEvily Attorney
Page Robinson Attorneys for Defendants
Shelby Hart-Armstrong Attorneys for Defendants
William George Attorneys for Plaintiffs
Stephen Lewis Attorney
Michael Martin Attorney
Richard Schwartz Attorney
Thomas Wilson Attorney
Tara Porterfield Attorney
Gary Johnson Attorneys for Defendants
Alton Todd Attorney
Stephanie Noble Attorney
Michael Leblanc Attorneys for Defendants
Frederick Black Attorneys for Defendants
John Malesovas Attorney
Kristin Brown Attorney
Philip Roberts Attorney
Ethan Baker Attorney

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Appellate Materials: Robert L Moody, Jr. vs. Greer, Herz, & Adams, LLP, Et Al

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