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FILED
8/14/2023 12:00 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Martin Reyes DEPUTY
NO. DC-20-08362
WILLIAM BECKER INDIVIDUALLY § IN THE DISTRICT COURT OF
AND AS TRUSTEE OF THE WILLIAM §
E. BECKER FAMILY TRUST AND §
SCOPE AUTOMOTIVE L.L.C., §
§
PLAINTIFFS/COUNTER- §
DEFENDANTS, § 95TH JUDICIAL DISTRICT
§
V. §
§
GEORGE BRYAN, §
§
DEFENDANT/COUNTER- §
PLAINTIFF. § DALLAS COUNTY, TEXAS
DEFENDANT’S MOTION FOR RECONSIDERATION AND/0R CLARIFICATION
TO THE HONORABLE JUDGE OF SAID COURT:
Defendant, George Bryan, files this Motion for Reconsideration and/or Clarification
of the Court’s ruling made on August 9, 2023 regarding Plaintiffs ’ Motion to Strike Defendant’s
Expert Max Wayman and Theories and Defendant’s Sixth Supplemental Disclosures (Plaintiffs’
“Motion”), and in support hereof shows the Court the following:
THE FACTS
Initially, Plaintiff set the hearing on Plaintiff’s Motion for August 9, 2023, the day
after lead counsel’s vacation, Counsel had a vacation letter on file requesting no hearings for three
(3) business days either side of his vacation. Accordingly, counsel enlisted the aid of his colleague,
John Morgan to respond the motion. Mr. Morgan was only recently enlisted into this case and
then to handle specific parts of the trial. Accordingly, lead counsel for Defendant did not brief or
make arguments regarding Plaintiffs’ Motion. Second, contrary to Plaintiffs’ arguments and
affirmative representations to the Court, almost all of the facts and legal theories contained within
Defendant’s Motion for Reconsideration or Clarification Page l
Defendant’s Sixth Supplemental Disclosures (the “Disclosures”) had been pleaded by Defendant
previously putting Plaintiffs on reasonable notice of Defendants contentions and defenses. Thus,
the facts and legal arguments contained Within the Disclosures were, in fact pleaded, and must be
allowed into evidence in the trial of this case. The specific facts and legal arguments contained
within the Disclosureswere previously pled as follows:
1. In Defendant’s First Amended Counterclaim filed on July 22, 2022, Defendant
states in paragraph l7: Becker took Saldana’s interest in Scope from Saldana, in
flagrant violation of the clear terms of the LLC Agreement and has been personally
operating Scope ever since. This is relevant to Bryan ’s Supplemental Disclosures
that claim Becker misrepresented his controlling interest in Scope and Becker’s
unauthorized transactions in breach of the LLC Agreement, creating Becker’s
own damages.
2. In Defendant’s First Amended Counterclaim filed on July 22, 2022, Defendant
states in paragraph 20: Over Bryan’s vehement objection, Scope entered into a
Servicing Agreement on April 12, 2018 with Cal-Tenn... As can be seen from the
Becker Affidavit, Becker, acting as the principal owner of Scope, allowed Cal-
Tenn to essentially move all of Scope’s assets to Tennessee. This is relevant to
Becker movedfull control of Scope to Cal-Tenn.
3. In Defendant’s First Amended Counterclaim filed on July 22, 2022, Defendant
states in paragraph 22: Six days after entering into the Cal-Tenn Servicing
Agreement, Becker, who had improperly acquired Saldana’s 30% interest in
Scope, and later also improperly acquired Eugene McKenzie’s 10% interest (so
that he now was the majority owner), demanded that Bryan resign... Since
Defendant’s Motion for Reconsideration or Clarification Page 2
terminating Bryan, Becker has installed his long-time personal bookkeeper
Jennifer O’Dell to be the Manager of Scope. Since taking over the operations of
Scope, Becker has utterly disregarded the Second Amended and Restated
Company Agreement of Scope Automotive LLC dated May 7, 2015 (the “LLC
Agreement”), essentially operating Scope out of his pocket as his own alter ego.
This is relevant to Becker tricked Bryan into resigning as a Manager of Scope,
Becker breached the LLC Agreement, and an illegal take over 0fprofits, losses,
assets and tax benefits from Bryan, Saldana and McKenzie.
4. In Defendant’s Fifth Amended Answer filed on January 10, 2023, Defendant states
in paragraph 2(c)(ii): On or about April 18, 2018, Becker demanded Bryan’s
resignation as Manager of Scope. This is relevant to Becker tricked Bryan into
resigning as a Manager of Scope.
5. In Defendant’s Fifth Amended Answer filed on January 10, 2023, Defendant states
in paragraph 2(f): Bryan denies liability for any losses of Scope or actions taken
by Scope after the date Becker forced Bryan to resign from Scope. All actions
taken by Scope, Becker, the Trust, any pseudo Manager of Scope, and/or any
owner or employee of Scope after Bryan resigned were outside of Bryan’s control,
consideration, and knowledge, including but not limited to any of Scope’s
financial losses, portfolio losses, note mismanagement, collections
mismanagement, reporting mismanagement, contracts with third parties, activities
with third parties, or losses, whether caused by any owner, employee, manager,
agent, representative or third party of Scope who were engaged in Scope, doing
business for or with Scope, or acting on behalf of or not on behalf of Scope, after
Defendant’s Motion for Reconsideration or Clarification Page 3
Bryan was forced to resign. This is relevant to Bryan ’s Supplemental Disclosures
factual and legal theories discussed above.
6. In Defendant’s Fifth Amended Answer filed on January 10, 2023, Defendant states
in paragraphs 2(k) and (1): Bryan pleads diminished liability based on the actions
taken by Becker and/or the Trust or Scope to remove Defendant from Scope and/or
dilute Defendant’s ownership interest and liability position in Scope. Bryan pleads
no liability for any and all actions taken by Becker, the Trust, Scope, or any
potentially responsible third party after Defendant was forced to resign from the
Company. This is relevant to Big/an ’s Supplemental Disclosures factual and legal
theories discussed above.
7. In Defendant’s Fifth Amended Answer filed on January 10, 2023, Defendant
pleads the following affirmative defenses in paragraphs 3(1), (i) and (j): Defendant
pleads the affirmative defense of Accord and Satisfaction in that on or about April
18, 2018, at a meeting at William Becker’s (“Becker”) offices at 7017 W. John
Carpenter Freeway, Dallas, Texas, Becker demanded Bryan’s resignation. At that
time Scope Automotive, LLC (“Scope”) was not in default of the Loan and was
solvent with positive cash flow. . .. Additionally, Becker took the interests of Adam
Saldana (“Saldana”) and Eugene McKenzie (“McKenzie”) in Scope from Saldana
and McKenzie, in flagrant violation and breach of the clear terms of the LLC
Agreement and has been personally operating Scope ever since. . .. Defendant
pleads the affirmative defense of Set Off. . .. Defendant pleads the affirmative
defense of Estoppel. This is relevant to Bryan ’s Supplemental Disclosures factual
and legal theories discussed above.
Defendant’s Motion for Reconsideration or Clarification Page 4
On July 14, 2023, more than 3O days before trial, Defendant timely filed his
supplemental disclosure which set forth Defendant’s factual arguments and theories based on
evidence produced previously in this case as well in the agreed-upon deposition of Plaintiff Becker,
which occurred on May 22, 2023. While Plaintiffs claim Defendant’s amended disclosures add
“new evidence” to this case, this is without any basis in fact. Defendant’s timely supplemental
disclosures did not add any “new evidence” to support Defendant’s factual contentions. It rather
timely supplemented Defendant’s “factual and legal theories” based on new findings derived from
permitted discovery. Further, all such supplemental matters contained in the Disclosures were
discovered by Defendant for the first time during the deposition of Scope, which was conducted
by agreement of the parties on May 22, 2023. The Disclosures were filed only forty-four (44) days
after the actual deposition (and approximately 30 days after the transcript was received) of Scope,
and were filed thirty-one (31) days prior to trial. Plaintiffs cite no authority supporting their
attempts to have this Court violate Defendant’s due process rights by excluding Defendant from
asserting his factual and legal theories at trial and making jury arguments based on the facts and
the law controlling this case. The facts upon which Defendant’s supplemental disclosures and
report are based were discovered during discovery, at a deposition that was conducted by
agreement, prior to the agreed upon discovery deadline, and Defendant’s disclosures were made
timely per Tex. R. Civ. P. 194.2 & 194.4
ARGUMENT
Since the Disclosures were based upon prior filings with this Court, the facts and defenses
pleaded within such Disclosures are admissible. Furthermore, evidence adduced from Plaintiff
Scope Automotive’s deposition occurring on May 22, 2023, should also be admissible. Lastly,
Defendant’s Motion for Reconsideration or Clarification Page 5
since Defendant timely served the Disclosures more than 30 days before trial, Defendant should
be allowed to argue the facts disclosed during Plaintiff Becker’s deposition. Plaintiffs’ request for
exclusion of Defendant’s timely disclosed factual assertions and legal theories asks this Court to
prevent Defendant from arguing his case, which is a Violation of Defendant’s right to due process,
and in Violation of Tex. R. Civ. P. l94.2(b)(3). Plaintiffs ask this Court to prevent Defendant from
informing the jury that Plaintiff Becker misrepresented his controlling interest in Scope
Automotive, which is a true statement and was pleaded (“improperly acquired his interest”).
Similarly, Plaintiff improperly asks this Court to exclude Defendant from explaining that Becker
engaged in unauthorized transactions in breach of the LLC Agreement, which was also pleaded,
and therefore Becker created his own damages. This assertion is based on facts adduced during
discovery, including the evidence adduced during Scope Automotive’s deposition, which directly
bears on Mr. Becker’s credibility and discredits Plaintiffs' case. Plaintiffs’ requested relief would
make a jury trial superfluous because Plaintiffs ask this Court to exclude any evidence or
arguments harmfiil to Plaintiffs and nullify Rule l94.2(b)(3). This request is essentially a death
penalty sanction in that it is equivalent to striking Defendant’s pleadings, preventing Defendant
from offering any defense, and requiring Defendant to agree with all of Plaintiffs’ assertions. This
would not only be reversible error, but also Defendant would be required to make multiple offers
of proof under Tex. R. Evid. 103, which would unduly prolong this trial.
CONCLUSION
For the reasons set forth above, Defendant requests that this Court grant Defendant’s
Motion for Reconsideration or Clarification of the Court’s ruling pertaining to Defendant’s Sixth
Supplemental Disclosures, and grant Defendant such other and further relief to which he may show
himself to be justly entitled.
Defendant’s Motion for Reconsideration or Clarification Page 6
Respectfully submitted,
/s/ Clark B. Will
CLARK B. WILL
Texas Bar No. 21502500
Law Office of Clark B. Will, P.C.
Member of the Firm
cbw@kilgorelaw.com
John S. Morgan
Of Counsel
Texas Bar No. 14447475
jsm@kilgorelaw.com
KILGORE & KILGORE, PLLC
3141 Hood Street, Suite 500
Dallas, Texas 75219
Telephone: (214) 969-9099
Telecopier: (214) 379-0843
ATTORNEYS FOR DEFENDANT
GEORGE BRYAN
CERTIFICATE OF SERVICE
I hereby certify a true and correct copy of the following document was forwarded to all
known counsel of record Via electronic filing pursuant to the Texas Rules of Civil Procedure on
this 12th day of August, 2023.
/s/ Clark B. Will
CLARK B. WILL
Defendant’s Motion for Reconsideration or Clarification Page 7
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.
Pat Milfeld on behalf of Clark Will
Bar No. 21502500
pam@kilgorelaw.com
Envelope ID: 78472270
Filing Code Description: Motion - Reconsider - $15
Filing Description: AND/OR CLARIFICATION
Status as of 8/14/2023 7:24 AM CST
Associated Case Party: SCOPE AUTOMOTIVE LLC
Name BarNumber Email TimestampSubmitted Status
Christopher JSchwegmann cschwegmann@lynnllp.com 8/12/2023 3:39:50 PM SENT
Victoria Kropp vkropp@|ynnllp.com 8/12/2023 3:39:50 PM SENT
Sara HollanChelette schelette@lynnllp.com 8/12/2023 3:39:50 PM SENT
NATALIE STALLBOHM nstallbohm@lynnllp.com 8/12/2023 3:39:50 PM SENT
SCOTT SMOOT ssmoot@|ynnllp.com 8/12/2023 3:39:50 PM SENT
Farsheed Fozouni ffozouni@|ynnllp.com 8/12/2023 3:39:50 PM SENT
Terra Brockway tbrockway@lynnllp.com 8/12/2023 3:39:50 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Edward SCox ed@edcoxlaw.com 8/12/2023 3:39:50 PM SENT
mary torres mary@edcoxlaw.com 8/12/2023 3:39:50 PM SENT
Jillian Chance jillian@edcoxlaw.com 8/12/2023 3:39:50 PM SENT
JOHN ADAMS JADAMS@LYNNLLP.COM 8/12/2023 3:39:50 PM ERROR
Associated Case Party: GEORGE BRYAN
Name BarNumber Email TimestampSubmitted Status
Patricia Milfeld pam@kilgorelaw.com 8/12/2023 3:39:50 PM SENT
Clark Will cbw@kilgorelaw.com 8/12/2023 3:39:50 PM SENT
John S.Morgan jsm@kilgorelaw.com 8/12/2023 3:39:50 PM SENT
Susan Witt saw@ki|gorelaw.com 8/ 12/2023 3:39:50 PM SENT
Preview
FILED 8/14/2023 12:00 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Martin Reyes DEPUTY NO. DC-20-08362 WILLIAM BECKER INDIVIDUALLY § IN THE DISTRICT COURT OF AND AS TRUSTEE OF THE WILLIAM § E. BECKER FAMILY TRUST AND § SCOPE AUTOMOTIVE L.L.C., § § PLAINTIFFS/COUNTER- § DEFENDANTS, § 95TH JUDICIAL DISTRICT § V. § § GEORGE BRYAN, § § DEFENDANT/COUNTER- § PLAINTIFF. § DALLAS COUNTY, TEXAS DEFENDANT’S MOTION FOR RECONSIDERATION AND/0R CLARIFICATION TO THE HONORABLE JUDGE OF SAID COURT: Defendant, George Bryan, files this Motion for Reconsideration and/or Clarification of the Court’s ruling made on August 9, 2023 regarding Plaintiffs ’ Motion to Strike Defendant’s Expert Max Wayman and Theories and Defendant’s Sixth Supplemental Disclosures (Plaintiffs’ “Motion”), and in support hereof shows the Court the following: THE FACTS Initially, Plaintiff set the hearing on Plaintiff’s Motion for August 9, 2023, the day after lead counsel’s vacation, Counsel had a vacation letter on file requesting no hearings for three (3) business days either side of his vacation. Accordingly, counsel enlisted the aid of his colleague, John Morgan to respond the motion. Mr. Morgan was only recently enlisted into this case and then to handle specific parts of the trial. Accordingly, lead counsel for Defendant did not brief or make arguments regarding Plaintiffs’ Motion. Second, contrary to Plaintiffs’ arguments and affirmative representations to the Court, almost all of the facts and legal theories contained within Defendant’s Motion for Reconsideration or Clarification Page l Defendant’s Sixth Supplemental Disclosures (the “Disclosures”) had been pleaded by Defendant previously putting Plaintiffs on reasonable notice of Defendants contentions and defenses. Thus, the facts and legal arguments contained Within the Disclosures were, in fact pleaded, and must be allowed into evidence in the trial of this case. The specific facts and legal arguments contained within the Disclosureswere previously pled as follows: 1. In Defendant’s First Amended Counterclaim filed on July 22, 2022, Defendant states in paragraph l7: Becker took Saldana’s interest in Scope from Saldana, in flagrant violation of the clear terms of the LLC Agreement and has been personally operating Scope ever since. This is relevant to Bryan ’s Supplemental Disclosures that claim Becker misrepresented his controlling interest in Scope and Becker’s unauthorized transactions in breach of the LLC Agreement, creating Becker’s own damages. 2. In Defendant’s First Amended Counterclaim filed on July 22, 2022, Defendant states in paragraph 20: Over Bryan’s vehement objection, Scope entered into a Servicing Agreement on April 12, 2018 with Cal-Tenn... As can be seen from the Becker Affidavit, Becker, acting as the principal owner of Scope, allowed Cal- Tenn to essentially move all of Scope’s assets to Tennessee. This is relevant to Becker movedfull control of Scope to Cal-Tenn. 3. In Defendant’s First Amended Counterclaim filed on July 22, 2022, Defendant states in paragraph 22: Six days after entering into the Cal-Tenn Servicing Agreement, Becker, who had improperly acquired Saldana’s 30% interest in Scope, and later also improperly acquired Eugene McKenzie’s 10% interest (so that he now was the majority owner), demanded that Bryan resign... Since Defendant’s Motion for Reconsideration or Clarification Page 2 terminating Bryan, Becker has installed his long-time personal bookkeeper Jennifer O’Dell to be the Manager of Scope. Since taking over the operations of Scope, Becker has utterly disregarded the Second Amended and Restated Company Agreement of Scope Automotive LLC dated May 7, 2015 (the “LLC Agreement”), essentially operating Scope out of his pocket as his own alter ego. This is relevant to Becker tricked Bryan into resigning as a Manager of Scope, Becker breached the LLC Agreement, and an illegal take over 0fprofits, losses, assets and tax benefits from Bryan, Saldana and McKenzie. 4. In Defendant’s Fifth Amended Answer filed on January 10, 2023, Defendant states in paragraph 2(c)(ii): On or about April 18, 2018, Becker demanded Bryan’s resignation as Manager of Scope. This is relevant to Becker tricked Bryan into resigning as a Manager of Scope. 5. In Defendant’s Fifth Amended Answer filed on January 10, 2023, Defendant states in paragraph 2(f): Bryan denies liability for any losses of Scope or actions taken by Scope after the date Becker forced Bryan to resign from Scope. All actions taken by Scope, Becker, the Trust, any pseudo Manager of Scope, and/or any owner or employee of Scope after Bryan resigned were outside of Bryan’s control, consideration, and knowledge, including but not limited to any of Scope’s financial losses, portfolio losses, note mismanagement, collections mismanagement, reporting mismanagement, contracts with third parties, activities with third parties, or losses, whether caused by any owner, employee, manager, agent, representative or third party of Scope who were engaged in Scope, doing business for or with Scope, or acting on behalf of or not on behalf of Scope, after Defendant’s Motion for Reconsideration or Clarification Page 3 Bryan was forced to resign. This is relevant to Bryan ’s Supplemental Disclosures factual and legal theories discussed above. 6. In Defendant’s Fifth Amended Answer filed on January 10, 2023, Defendant states in paragraphs 2(k) and (1): Bryan pleads diminished liability based on the actions taken by Becker and/or the Trust or Scope to remove Defendant from Scope and/or dilute Defendant’s ownership interest and liability position in Scope. Bryan pleads no liability for any and all actions taken by Becker, the Trust, Scope, or any potentially responsible third party after Defendant was forced to resign from the Company. This is relevant to Big/an ’s Supplemental Disclosures factual and legal theories discussed above. 7. In Defendant’s Fifth Amended Answer filed on January 10, 2023, Defendant pleads the following affirmative defenses in paragraphs 3(1), (i) and (j): Defendant pleads the affirmative defense of Accord and Satisfaction in that on or about April 18, 2018, at a meeting at William Becker’s (“Becker”) offices at 7017 W. John Carpenter Freeway, Dallas, Texas, Becker demanded Bryan’s resignation. At that time Scope Automotive, LLC (“Scope”) was not in default of the Loan and was solvent with positive cash flow. . .. Additionally, Becker took the interests of Adam Saldana (“Saldana”) and Eugene McKenzie (“McKenzie”) in Scope from Saldana and McKenzie, in flagrant violation and breach of the clear terms of the LLC Agreement and has been personally operating Scope ever since. . .. Defendant pleads the affirmative defense of Set Off. . .. Defendant pleads the affirmative defense of Estoppel. This is relevant to Bryan ’s Supplemental Disclosures factual and legal theories discussed above. Defendant’s Motion for Reconsideration or Clarification Page 4 On July 14, 2023, more than 3O days before trial, Defendant timely filed his supplemental disclosure which set forth Defendant’s factual arguments and theories based on evidence produced previously in this case as well in the agreed-upon deposition of Plaintiff Becker, which occurred on May 22, 2023. While Plaintiffs claim Defendant’s amended disclosures add “new evidence” to this case, this is without any basis in fact. Defendant’s timely supplemental disclosures did not add any “new evidence” to support Defendant’s factual contentions. It rather timely supplemented Defendant’s “factual and legal theories” based on new findings derived from permitted discovery. Further, all such supplemental matters contained in the Disclosures were discovered by Defendant for the first time during the deposition of Scope, which was conducted by agreement of the parties on May 22, 2023. The Disclosures were filed only forty-four (44) days after the actual deposition (and approximately 30 days after the transcript was received) of Scope, and were filed thirty-one (31) days prior to trial. Plaintiffs cite no authority supporting their attempts to have this Court violate Defendant’s due process rights by excluding Defendant from asserting his factual and legal theories at trial and making jury arguments based on the facts and the law controlling this case. The facts upon which Defendant’s supplemental disclosures and report are based were discovered during discovery, at a deposition that was conducted by agreement, prior to the agreed upon discovery deadline, and Defendant’s disclosures were made timely per Tex. R. Civ. P. 194.2 & 194.4 ARGUMENT Since the Disclosures were based upon prior filings with this Court, the facts and defenses pleaded within such Disclosures are admissible. Furthermore, evidence adduced from Plaintiff Scope Automotive’s deposition occurring on May 22, 2023, should also be admissible. Lastly, Defendant’s Motion for Reconsideration or Clarification Page 5 since Defendant timely served the Disclosures more than 30 days before trial, Defendant should be allowed to argue the facts disclosed during Plaintiff Becker’s deposition. Plaintiffs’ request for exclusion of Defendant’s timely disclosed factual assertions and legal theories asks this Court to prevent Defendant from arguing his case, which is a Violation of Defendant’s right to due process, and in Violation of Tex. R. Civ. P. l94.2(b)(3). Plaintiffs ask this Court to prevent Defendant from informing the jury that Plaintiff Becker misrepresented his controlling interest in Scope Automotive, which is a true statement and was pleaded (“improperly acquired his interest”). Similarly, Plaintiff improperly asks this Court to exclude Defendant from explaining that Becker engaged in unauthorized transactions in breach of the LLC Agreement, which was also pleaded, and therefore Becker created his own damages. This assertion is based on facts adduced during discovery, including the evidence adduced during Scope Automotive’s deposition, which directly bears on Mr. Becker’s credibility and discredits Plaintiffs' case. Plaintiffs’ requested relief would make a jury trial superfluous because Plaintiffs ask this Court to exclude any evidence or arguments harmfiil to Plaintiffs and nullify Rule l94.2(b)(3). This request is essentially a death penalty sanction in that it is equivalent to striking Defendant’s pleadings, preventing Defendant from offering any defense, and requiring Defendant to agree with all of Plaintiffs’ assertions. This would not only be reversible error, but also Defendant would be required to make multiple offers of proof under Tex. R. Evid. 103, which would unduly prolong this trial. CONCLUSION For the reasons set forth above, Defendant requests that this Court grant Defendant’s Motion for Reconsideration or Clarification of the Court’s ruling pertaining to Defendant’s Sixth Supplemental Disclosures, and grant Defendant such other and further relief to which he may show himself to be justly entitled. Defendant’s Motion for Reconsideration or Clarification Page 6 Respectfully submitted, /s/ Clark B. Will CLARK B. WILL Texas Bar No. 21502500 Law Office of Clark B. Will, P.C. Member of the Firm cbw@kilgorelaw.com John S. Morgan Of Counsel Texas Bar No. 14447475 jsm@kilgorelaw.com KILGORE & KILGORE, PLLC 3141 Hood Street, Suite 500 Dallas, Texas 75219 Telephone: (214) 969-9099 Telecopier: (214) 379-0843 ATTORNEYS FOR DEFENDANT GEORGE BRYAN CERTIFICATE OF SERVICE I hereby certify a true and correct copy of the following document was forwarded to all known counsel of record Via electronic filing pursuant to the Texas Rules of Civil Procedure on this 12th day of August, 2023. /s/ Clark B. Will CLARK B. WILL Defendant’s Motion for Reconsideration or Clarification Page 7 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. Pat Milfeld on behalf of Clark Will Bar No. 21502500 pam@kilgorelaw.com Envelope ID: 78472270 Filing Code Description: Motion - Reconsider - $15 Filing Description: AND/OR CLARIFICATION Status as of 8/14/2023 7:24 AM CST Associated Case Party: SCOPE AUTOMOTIVE LLC Name BarNumber Email TimestampSubmitted Status Christopher JSchwegmann cschwegmann@lynnllp.com 8/12/2023 3:39:50 PM SENT Victoria Kropp vkropp@|ynnllp.com 8/12/2023 3:39:50 PM SENT Sara HollanChelette schelette@lynnllp.com 8/12/2023 3:39:50 PM SENT NATALIE STALLBOHM nstallbohm@lynnllp.com 8/12/2023 3:39:50 PM SENT SCOTT SMOOT ssmoot@|ynnllp.com 8/12/2023 3:39:50 PM SENT Farsheed Fozouni ffozouni@|ynnllp.com 8/12/2023 3:39:50 PM SENT Terra Brockway tbrockway@lynnllp.com 8/12/2023 3:39:50 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Edward SCox ed@edcoxlaw.com 8/12/2023 3:39:50 PM SENT mary torres mary@edcoxlaw.com 8/12/2023 3:39:50 PM SENT Jillian Chance jillian@edcoxlaw.com 8/12/2023 3:39:50 PM SENT JOHN ADAMS JADAMS@LYNNLLP.COM 8/12/2023 3:39:50 PM ERROR Associated Case Party: GEORGE BRYAN Name BarNumber Email TimestampSubmitted Status Patricia Milfeld pam@kilgorelaw.com 8/12/2023 3:39:50 PM SENT Clark Will cbw@kilgorelaw.com 8/12/2023 3:39:50 PM SENT John S.Morgan jsm@kilgorelaw.com 8/12/2023 3:39:50 PM SENT Susan Witt saw@ki|gorelaw.com 8/ 12/2023 3:39:50 PM SENT