Preview
Filed: 1/31/2020 3:55 PM
JOHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 40472828
By: Lisa Kelly
1/31/2020 4:38 PM
CAUSE NO. 19-CV-1864
TOD LAY AND SHANNON LAY, § IN THE DISTRICT COURT OF
§
Plaintiffs, §
§
v. §
§
§ GALVESTON COUNTY, TEXAS
NATIONSTAR MORTGAGE LLC §
D/B/A MR. COOPER SUCCESSOR BY §
MERGER TO PACIFIC UNION §
FINANCIAL, LLC, §
§
Defendant. § 212th JUDICIAL DISTRICT
PLAINTIFFS’ UNOPPOSED MOTION TO RELEASE BOND
TO THE HONORABLE COURT:
There is currently on deposit in the Registry of the Court funds being held as ordered by
the Court during the pendency of the above styled case. This case was dismissed on January 28,
2020. See Agreed Order of Dismissal with Prejudice, attached as Exhibit 1.
Plaintiff requests that the Court disburse to the Lane Law Firm, the one thousand dollars
and 00/100 bond ($1,000.00) previously posted on the above referenced matter after adding or
deducting any interest or fees that the Clerk is required to add or deduct. Nationstar Mortgage,
LLC d/b/a Mr. Cooper Successor by Merger to Pacific Union Financial, LLC, the party previously
restrained by the temporary restraining order, has no opposition to the release of these funds back
to Plaintiffs’ counsel.
The check can be made payable to the following:
1
Robert C. Lane
c/o The Lane Law Firm, P.L.L.C.
6200 Savoy Drive, Suite 1150
Houston, TX 77036
Respectfully submitted this 31st day of January 2020,
THE LANE LAW FIRM, P.L.L.C.
By: /s/ Robert C. Lane
Robert “Chip” C. Lane
State Bar No. 24046263
notifications@lanelaw.com
Joshua D. Gordon
State Bar No. 24091592
joshua.gordon@lanelaw.com
6200 Savoy Drive, Suite 1150
Houston, Texas 77036
Telephone: (713) 595-8200
Facsimile: (713) 595-8201
ATTORNEY FOR PLAINTIFF
CERTIFICATE OF CONFERENCE
On January 30, 2020, my firm conferred with the attorney of record for the Defendant to
see whether or not they were opposed to the above motion. Defendant is unopposed.
By: /s/ Robert C. Lane
Robert “Chip” C. Lane
2
CERTIFICATE OF SERVICE
I hereby certify that on the 31 day of January 2020, a true and correct copy of the above
and foregoing instrument has been served upon the following, via ECF notification:
HEATHER N. SUTTON
SBN: 24072378
hsutton@mcguirewoods.com
MCGUIREWOODS LLP
2000 McKinney Avenue, Suite 1400
Dallas, Texas 75201
Telephone: 214.932.6400
Facsimile: 214.932.6499
ATTORNEY FOR DEFENDANT
By: /s/ Robert C. Lane
Robert “Chip” C. Lane
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redd 1'724/2020 3:55 PM
Envelope No. 40267971
CAUSE N0. 19-CV-1864
20 JAN 30 M4. l0: SS
TOD W. LAY and SHANNON LAY, § IN THE DISTRICT COU T OF
. .
§ WW.“ 4;;
‘
Plamtsz, § / 913mm CLERK
§ GALVESTCH caimv TEXAS
v. §
212‘“ JUDICIAL DISTRICT
§
NATIONSTAR MORTGAGE LLC d/b/a §
MR COOPER SUCCESSOR BY §
MERGER TO PACIFIC UNION §
FINANCIAL LLC, §
§ .
Defendant. § GALVESTON COUNTY, TEXAS
AGREED ORDER OF DISMISSAL WITH PREJUDICE
Now before the Court is an Agreed Motion to Dismiss (“Motion”) filed by Plaintiffs Tod
W. Lay and Shannon Lay (“Plaintiffs”) and Defendant Nationstar Mortgage LLC d/b/a
Successor by Merger to Pacific Union Financial LLC (“Defendant”) (individually a “Party” or
collectively, the “Parties”). After due consideration, the Court is 0f the opinion that said Motion
t
is well taken and should be in all things GRANTED.
IT IS THEREFORE ORDERED that all claims asserted by Plaintiffs against
Defendant are dismissed with prejudice.
IT IS FURTHER ORDERED that each Party shall bear its own costs of court and
attomeys’ fees.
IT IS FURTHER ORDERED that all reliefnot expressly granted between Plaintiffs and
Defendant is hereby denied. This is a final judgment.
SIGNED this 2K day of \ £17k ,2020.
JUDGE PRESIDING .
__
19-CV—1864
DCAGOD
Dismissal —-
.
Final — OCA
Agreed Order of
1979120
l
AGREED ORDER OF DISMISSAL WITH PREJUDICE l
Cause No. 19-CV-1864; Tod W. Lay, eI al. v. Nationsrar Mortgage, LLC ‘
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SUBMITTED BY:
/S/ Heather N. Sutton
HEATHER N. SUTTON, SBN: 24072378
hsutton@mcguirewoodscomm
MCGUIREWOODS LLP
2000 McKinney Avenue, Suite 1400
Dallas, Texas 75201
ATTORNEY FOR DEFENDANT
NATIONSTAR MORTGAGE LLC
D/B/A MR. COOPER SUCCESSOR
BY MERGER TO PACIFIC
UNION FINANCIAL LLC
/S/ Joshua D. Gordon
JOSHUA D. GORDON, SBN: 24091 592
ioshua.gordongfiilanelawzcom
Robert “Chip” C. Lane
chip.lane@lanelaw.com
THE LANE LAW FIRM, P.L.L.C.
6200 Savoy Drive, Suite 1150
Houston, Texas 77036
ATTORNEYS FOR PLAINTIFFS
TOD W. LAY AND SHANNON LAY
AGREED ORDER OF DISMISSAL WITH PREJUDICE Page 2 0f2
Cause No, I9-CV-l864; Tod W, Lay. e1 al. v, Nanonslar Mortgage. LLC