On November 21, 2022 a
RULE 11 AGREEMENT RE: EXTEND DEADLINE - RULE 11
was filed
involving a dispute between
Khol Company Llc,,
and
Berry, James,
Silica Group, Llc,
Transload And Logistics, Llc,
Transload Sand Sales, Llc,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
Preview
FILED
10/2/2023 2:56 PM
FELICIA PITRE
THE FEIN LAW FIRM, P.C. DISTRICT CLERK
DALLAS CO., TEXAS
ATTORNEYS AND COUNSELORS AT LAW Margaret Thomas DEPUTY
15455 North Dallas Parkway, Suite 540
Addison, Texas 75001
Tr'Lr' Telephone
Via E-Mail and E-File
214-522-9596 '
Facsimile 214-522-9599
October 10, 2023
Jeffery H. Rusthoven
NIXON JACH HUBBARD, PLLC
Crescent International Plaza III
14241 Dallas Parkway, suite 575
Dallas, Texas 7524-22-5
ERIC D. FEIN jrusthoven©nih-law.com
Member of Texas, Illinois,
California & New York Bars
Re: CAUSE NO. DC—22-16109: Khol Company, LLC v. Transload and Logistics, LLC
and Jim Berry, pending in the 193m Judicial District Court, Dallas County, Texas
VICKIE S. BRANDT
Member of Texas Bar
RULE 11 AGREEMENT
Dear Counsel:
OF COUNSEL: This will constitute our agreement reached on October 2, 2023 wherein you, on
HILDA HAHN MORALEs behalf of the Defendant James Berry, agreed to extend the deadline by seven (7) days
Member of Texas Bar for Plaintiff to provide its objections and responses to Defendant James Berry’s
Written Discovery Requests (First Set of Interrogatories and Requests for
Production). The discovery was originally due on September 3, 2023 and now
extended to October 10, 2023. Plaintiff s Objections and Responses to Defendant
James Berry’s First Set of Interrogatories and Requests for Production will now be
due on October 10, 2023.
If this conforms with your understanding of our agreement, please sign below
and we will file the Rule 11 Agreement with the Court. Thank you for your
courtesies.
Very truly yours,
Eric D. Fein
DALLAS OFFICE
15455 N. Dallas Parkway
Suite 540
Addison, Texas 75001
(214) 522-9596 Telephone
AGREED:
(214) 522-9599 Facsimile
NEW YORK OFFICE
305 Broadway
(JIM/flown
H Rusthoven
Suite 700
New York, N.Y. 10007
(212) 323-6888 Telephone
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.
Vickie Brandt on behalf of Eric Fein
Bar No. 06879020
vbrandt@feinlawfirm.com
Envelope ID: 80156921
Filing Code Description: Rule 11
Filing Description: RE: EXTEND DEADLINE
Status as of 10/2/2023 3:16 PM CST
Associated Case Party: KHOL COMPANY LLC,
Name BarNumber Email Timestam pSubmitted Status
ERIC DFEIN efein@feinlawfirm.com 10/2/2023 2:56:59 PM SENT
Case Contacts
Name BarNumber Email Timestam pSubmitted Status
Jeffery HRusthoven jrusthoven@njh-law.com 10/2/2023 2:56:59 PM SENT
Vickie SBrandt vbrandt@feinlawfirm.com 10/2/2023 2:56:59 PM SENT
Legal Assistant legalassistant@feinlawfirm.com 10/2/2023 2:56:59 PM SENT
Jennifer Hubbard jhubbard@njh-law.com 10/2/2023 2:56:59 PM SENT
Document Filed Date
October 02, 2023
Case Filing Date
November 21, 2022
Category
CNTR CNSMR COM DEBT
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED 10/2/2023 2:56 PM FELICIA PITRE THE FEIN LAW FIRM, P.C. DISTRICT CLERK DALLAS CO., TEXAS ATTORNEYS AND COUNSELORS AT LAW Margaret Thomas DEPUTY 15455 North Dallas Parkway, Suite 540 Addison, Texas 75001 Tr'Lr' Telephone Via E-Mail and E-File 214-522-9596 ' Facsimile 214-522-9599 October 10, 2023 Jeffery H. Rusthoven NIXON JACH HUBBARD, PLLC Crescent International Plaza III 14241 Dallas Parkway, suite 575 Dallas, Texas 7524-22-5 ERIC D. FEIN jrusthoven©nih-law.com Member of Texas, Illinois, California & New York Bars Re: CAUSE NO. DC—22-16109: Khol Company, LLC v. Transload and Logistics, LLC and Jim Berry, pending in the 193m Judicial District Court, Dallas County, Texas VICKIE S. BRANDT Member of Texas Bar RULE 11 AGREEMENT Dear Counsel: OF COUNSEL: This will constitute our agreement reached on October 2, 2023 wherein you, on HILDA HAHN MORALEs behalf of the Defendant James Berry, agreed to extend the deadline by seven (7) days Member of Texas Bar for Plaintiff to provide its objections and responses to Defendant James Berry’s Written Discovery Requests (First Set of Interrogatories and Requests for Production). The discovery was originally due on September 3, 2023 and now extended to October 10, 2023. Plaintiff s Objections and Responses to Defendant James Berry’s First Set of Interrogatories and Requests for Production will now be due on October 10, 2023. If this conforms with your understanding of our agreement, please sign below and we will file the Rule 11 Agreement with the Court. Thank you for your courtesies. Very truly yours, Eric D. Fein DALLAS OFFICE 15455 N. Dallas Parkway Suite 540 Addison, Texas 75001 (214) 522-9596 Telephone AGREED: (214) 522-9599 Facsimile NEW YORK OFFICE 305 Broadway (JIM/flown H Rusthoven Suite 700 New York, N.Y. 10007 (212) 323-6888 Telephone 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. Vickie Brandt on behalf of Eric Fein Bar No. 06879020 vbrandt@feinlawfirm.com Envelope ID: 80156921 Filing Code Description: Rule 11 Filing Description: RE: EXTEND DEADLINE Status as of 10/2/2023 3:16 PM CST Associated Case Party: KHOL COMPANY LLC, Name BarNumber Email Timestam pSubmitted Status ERIC DFEIN efein@feinlawfirm.com 10/2/2023 2:56:59 PM SENT Case Contacts Name BarNumber Email Timestam pSubmitted Status Jeffery HRusthoven jrusthoven@njh-law.com 10/2/2023 2:56:59 PM SENT Vickie SBrandt vbrandt@feinlawfirm.com 10/2/2023 2:56:59 PM SENT Legal Assistant legalassistant@feinlawfirm.com 10/2/2023 2:56:59 PM SENT Jennifer Hubbard jhubbard@njh-law.com 10/2/2023 2:56:59 PM SENT