Preview
FILED
4/19/2024 2:24 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Cheryl Watts DEPUTY
DC-24-05809
CAUSE NO.
ANA M. ROMERO AND § IN THE DISTRICT COURT
JOSE A. ROMERO §
§
Plaintiffs, §
§ 14th
v. § ________ JUDICIAL DISTRICT
§
U.S. BANK TRUST NATIONAL §
ASSOCIATION, IN ITS INDIVIDUAL §
CAPACITY AND AS OWNER TRUSTEE §
FOR RCF 2 ACQUISITION TRUST §
§
Defendants. § DALLAS COUNTY, TEXAS
PLAINTIFFS’ ORIGINAL PETITION
TO THE HONORABLE COURT:
COME NOW, Ana M. Romero and Jose A. Romero (the “Plaintiffs”), and file their
Plaintiffs’ Original Petition against Defendant U.S. Bank Trust National Association, in its
individual capacity and in its capacity as Owner Trustee for RCF 2 Acquisition Trust (the
“Mortgagee” or “Defendant”), and would respectfully show the following:
I.
DISCOVERY CONTROL PLAN
Plaintiffs intend to conduct discovery under Level 2 of Rule 190.
II.
RULE 47 STATEMENTS
In accordance with Tex. R. Civ. P. 47, Plaintiffs state that:
a. Plaintiffs sue Defendant to challenge its attempted foreclosure and enforcement of a
discharged Home Equity Loan previously secured by their real property,
b. The damages sought are within the jurisdictional limits of this Court, and
c. Plaintiffs demand judgment for all other relief to which Plaintiffs may be justly entitled.
PLAINTIFFS’ ORIGINAL PETITION Page 1
14404241v1
10257.058
III.
PARTIES
1. Ana M. Romero and Jose A. Romero (the “Plaintiffs”) are individuals who reside
at 524 Erikson Trail, Irving, TX 75060 in Dallas County, Texas.
2. Defendant U.S. Bank Trust National Association, is a foreign corporate fiduciary
and may be served with process by serving its Registered Agent, Selene Finance, at 3501 Olympus
Blvd, 5th Floor, Suite 500, Dallas, TX 75019.
IV.
JURISDICTION AND VENUE
3. This Court has jurisdiction under Chapters 31 and 32 of the Texas Estates Code.
Venue is proper and mandatory in this County because (b) the real property that is the subject of
this suit is located in this County.1
V.
FACTS
4. On or about August 30, 2018, Harrison Major (“Mortgagor”) took out a Home
Equity Loan (the “Loan”) secured by 524 Erikson Trail, Irving, 75060 (the “Property”), with the
following legal description:
Being Lot in Block “E” of Kensington Estates, an Addition to the City of
Irving, Dallas County, Texas, according to the Map or Plat Thereof Recorded
in Volume 78053, Page 2049 of the Map Records of Dallas County, Texas,
Defendant is the current holder of the Loan.
5. On September 12, 2018, Bank of America prepared the Home Equity Line of Credit
Security Instrument (the “Security”), which allegedly secured the Loan with the Property.
6. On or about November 9, 2020, the Mortgagor died. Pursuant to an Affidavit of
Heirship recorded at Document No. 202000352962, in the Official Public Records of Dallas
1
Tex. Civ. Prac. & Rem. Code §15.011.
PLAINTIFFS’ ORIGINAL PETITION Page 2
14404241v1
10257.058
County, Texas, the Mortgagor had one child, Jennifer Rasberry, and two stepchildren, Carrie Jo
Dean and Tammie Lynn Williams.
7. Carrie Jo Dean and Tammie Lynn Williams possessed an interest in the Property
and each subsequently deeded their interest to Jennifer Rasberry via a General Warranty Deed
recorded on December 17, 2020 as Document No. 202000352963 in the Official Public Records
of Dallas County, Texas.
8. Jennifer Rasberry then deeded the entire Property to SDal Holdings LLC (“SDal”)
via a General Warranty Deed recorded on December 17, 2020 as Document No. 202000352964,
in the Official Public Records of Dallas County, Texas. The title company utilized to close this
transaction was Community National Title, LLC (“CNAT”).
9. At CNAT’s request and on November 23, 2020, Bank of America provided CNAT
a payoff calculation for the Loan good through December 23, 2020 (the “Payoff Letter”). The
Payoff Letter calculated the sum needed to pay off all indebtedness to be $58,819.55, and it is the
only payoff quote that Bank of America ever issued in response to CNAT’s request for a complete
payoff amount for the Loan.
10. On December 16, 2020, CNAT wired Bank of America $58,819.55 to pay off the
Loan in accordance with the Payoff Letter. It is undisputed that CNAT’s payment was timely, that
the payment was for the entire sum quoted by Bank of America, and that the payment was made
pursuant to all terms of the Payoff Letter. It is Plaintiffs’ understanding that after this payment was
made, Bank of America assigned its entire interest in the Loan to Defendant.
11. SDal next deeded the Property to Miguel A. Hernandez via a Special Warranty
Deed recorded on December 18, 2020 as Document No. 202000354597, in the Official Public
Records of Dallas County, Texas.
PLAINTIFFS’ ORIGINAL PETITION Page 3
14404241v1
10257.058
12. Miguel A. Hernandez then deeded the Property to the Plaintiffs via a Warranty
Deed with Vender’s Lien recorded on March 29, 2022 as Document No. 202200085985, in the
Official Public Records of Dallas County, Texas.
13. Two and a half years after CNAT’s payment and in spite of the Loan being paid off
in full, Defendant initiated an expedited judicial foreclosure proceeding against Plaintiffs under
Texas Rules of Civil Procedure 735 and 736 on June 1, 2023 (the “736 Action”).2 In its application,
Defendant averred that Plaintiffs – not the Mortgagor – were in default of the terms of the Loan
because 30 regular monthly payments had not been paid. Defendant alleges that the total amount
remaining to pay off the Loan is $41,189.57, but is unable to identify any evidence that the Loan
was not satisfied in full by CNAT’s payment in accordance with the Payoff Letter on December
16, 2020.
14. A hearing for the 736 Action is set for April 25, 2024.
VI.
CAUSES OF ACTION
A. Suit to Quiet Title
15. Plaintiffs reallege and incorporate all previous paragraphs as if fully set forth
herein.
16. The elements for a suit to quiet title are: (a) an interest in a specific property, (b)
title to the property is affected by a claim by the defendant, and (c) that the claim, although facially
valid, is invalid or unenforceable. Vernon v. Perrien, 390 S.W.3d 47 (Tex. App. -- El Paso 2012,
review denied).
17. Defendant claims the Security is their interest in the Property and argue that it forms
the basis of the 736 Action and Defendant’s attempt to sell the Property at foreclosure auction.
2
Cause No. 096-348666-23, in the 96th District Court of Tarrant County, Texas.
PLAINTIFFS’ ORIGINAL PETITION Page 4
14404241v1
10257.058
Plaintiffs’ title to the Property is affected by Defendant’s claim that it has a right to foreclose
because the Loan was supposedly not paid off. However, the Security sought to be foreclosed is
invalid or unenforceable because the Loan secured by the Property was paid off on December 16,
2020, pursuant to Bank of America’s Payoff Letter.
18. Defendant’s claim that the Loan has an outstanding balance of $41,189.57 and that
it is entitled to foreclose on the Property constitutes a cloud and impediment on Plaintiffs’ title to
the Property. Because the Loan has been satisfied, the Security and Defendant’s claim are each
invalid. Plaintiffs request that title to the Property be quieted in favor of Plaintiffs, free and clear
of the Loan, the Security, and all related security instruments or liens.
B. Declaratory Judgment
19. Plaintiffs reallege and incorporate all previous paragraphs as if fully set forth
herein.
20. Plaintiffs and Defendant have a justiciable controversy concerning whether (a) the
Defendant has a present right to foreclose on the Property; and (b) whether all security for and
liens arising from the Loan are valid and enforceable.
21. Defendant’s predecessor in interest issued the Payoff Letter to CNAT on November
23, 2020, stating that the remaining balance on the Security secured by the Property was
$58,819.55, and requiring payment of that sum on or before December 23, 2020. It is undisputed
that on December 16, 2020, and in accordance with the Payoff Letter, CNAT wired Defendant’s
predecessor in interest the sum of $58,819.55.
22. By accepting an assignment of the Security and the Loan, Defendant stepped into
the shoes of its predecessor in interest, and Defendant’s rights were therefore affected by CNAT’s
PLAINTIFFS’ ORIGINAL PETITION Page 5
14404241v1
10257.058
payment. As a result, Plaintiffs seek a declaration that the Loan, the Security, and Defendant’s
right to foreclose have been extinguished by CNAT’s satisfaction of the terms of the Payoff Letter.
23. In the alternative, Plaintiffs seek a declaration that Defendant is equitably estopped
from enforcing the terms of the Loan, the Security, or their right to foreclose because on November
23, 2020, Defendant’s predecessor expressly represented that the sum of $58,819.55 was needed
to pay off the Loan and discharge the Security. Defendant stepped into the shoes of its predecessor
who made that representation, which was relied on by CNAT and the Plaintiffs to their detriment.
Defendant is now estopped from claiming a different sum was needed to satisfy the Loan over and
above the sum identified in the Payoff Letter to CNAT on November 23, 2020.
24. Therefore, Plaintiffs respectfully request this Court enter judgment declaring that
Defendant is estopped from attempting to foreclose on the Property or otherwise claiming that it
can enforce the terms of the Loan or the Security against Plaintiffs or the Property.
D. Claim for Attorneys’ Fees and Costs
25. Plaintiffs request and are entitled to recovery of their reasonable and necessary
attorney fees, expenses, and costs incurred in the prosecution of their claims herein pursuant to
Texas Civil Practice and Remedies Code section 37.009.
26. Plaintiffs further seek recovery of pre and post judgment interest at the maximum
amount permitted by Texas law.
VII.
STAY OF FORECLOSURE UNDER TEXAS RULE OF CIVIL PROCEDURE 736.11
27. Plaintiffs reallege and incorporate all previous paragraphs as if fully set forth
herein.
PLAINTIFFS’ ORIGINAL PETITION Page 6
14404241v1
10257.058
28. This lawsuit is a separate, original proceeding that puts into issue the enforcement
of the loan agreement, contract, or lien sought to be foreclosed, specifically, the Security and the
Loan. Therefore, pursuant to Texas Rule of Civil Procedure 736.11, the 736 Action must be
automatically stayed through a trial on the merits of the captioned cause.
VIII.
PRAYER
WHEREFORE PREMISES CONSIDERED, Plaintiffs pray that Defendant be cited to
appear and answer and that, after final hearing or trial, the Court enter a judgment:
a. Title to the Property is quieted in favor of Plaintiffs;
b. Declaring that the Loan, the Security, and Defendant’s right to foreclose have been
extinguished;
c. Declaring that Defendant is estopped from attempting to foreclose on the Property
or otherwise claiming that it can enforce the terms of the Loan or the Security
against Plaintiffs or the Property,
d. Awarding Plaintiffs their reasonable and necessary attorneys’ fees incurred in
prosecuting Plaintiffs’ claims through trial and, if necessary, through appeal, plus
costs of court, and
e. Awarding Plaintiffs such other relief, at law or in equity, to which Plaintiffs may
be justly entitled.
PLAINTIFFS’ ORIGINAL PETITION Page 7
14404241v1
10257.058
Respectfully submitted,
THOMPSON, COE, COUSINS & IRONS, L.L.P.
By: /s/ Matt R. Daigle .
Craig L. Dowis
State Bar No. 24043743
cdowis@thompsoncoe.com
Matt R. Daigle
State Bar No. 24043743
mdaigle@thompsoncoe.com
Kayla F. Aitken
State Bar No. 24115429
kaitken@thompsoncoe.com
Plaza of the Americas
700 N. Pearl Street, Twenty-Fifth Floor
Dallas, TX 75201-2832
Telephone: (214) 871-8200
Facsimile: (214) 871-8209
ATTORNEYS FOR PLAINTIFFS
PLAINTIFFS’ ORIGINAL PETITION Page 8
14404241v1
10257.058
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.
Megan Mantas on behalf of Craig Dowis
Bar No. 24028655
MMantas@thompsoncoe.com
Envelope ID: 86866084
Filing Code Description: Original Petition
Filing Description:
Status as of 4/24/2024 3:31 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Craig Dowis cdowis@thompsoncoe.com 4/19/2024 2:24:43 PM SENT
Megan Mantas mmantas@thompsoncoe.com 4/19/2024 2:24:43 PM SENT
Vivian Demianiw vdemianiw@thompsoncoe.com 4/19/2024 2:24:43 PM SENT
Matt Daigle mdaigle@thompsoncoe.com 4/19/2024 2:24:43 PM SENT
Preview
FILED 4/19/2024 2:24 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Cheryl Watts DEPUTY DC-24-05809 CAUSE NO. ANA M. ROMERO AND § IN THE DISTRICT COURT JOSE A. ROMERO § § Plaintiffs, § § 14th v. § ________ JUDICIAL DISTRICT § U.S. BANK TRUST NATIONAL § ASSOCIATION, IN ITS INDIVIDUAL § CAPACITY AND AS OWNER TRUSTEE § FOR RCF 2 ACQUISITION TRUST § § Defendants. § DALLAS COUNTY, TEXAS PLAINTIFFS’ ORIGINAL PETITION TO THE HONORABLE COURT: COME NOW, Ana M. Romero and Jose A. Romero (the “Plaintiffs”), and file their Plaintiffs’ Original Petition against Defendant U.S. Bank Trust National Association, in its individual capacity and in its capacity as Owner Trustee for RCF 2 Acquisition Trust (the “Mortgagee” or “Defendant”), and would respectfully show the following: I. DISCOVERY CONTROL PLAN Plaintiffs intend to conduct discovery under Level 2 of Rule 190. II. RULE 47 STATEMENTS In accordance with Tex. R. Civ. P. 47, Plaintiffs state that: a. Plaintiffs sue Defendant to challenge its attempted foreclosure and enforcement of a discharged Home Equity Loan previously secured by their real property, b. The damages sought are within the jurisdictional limits of this Court, and c. Plaintiffs demand judgment for all other relief to which Plaintiffs may be justly entitled. PLAINTIFFS’ ORIGINAL PETITION Page 1 14404241v1 10257.058 III. PARTIES 1. Ana M. Romero and Jose A. Romero (the “Plaintiffs”) are individuals who reside at 524 Erikson Trail, Irving, TX 75060 in Dallas County, Texas. 2. Defendant U.S. Bank Trust National Association, is a foreign corporate fiduciary and may be served with process by serving its Registered Agent, Selene Finance, at 3501 Olympus Blvd, 5th Floor, Suite 500, Dallas, TX 75019. IV. JURISDICTION AND VENUE 3. This Court has jurisdiction under Chapters 31 and 32 of the Texas Estates Code. Venue is proper and mandatory in this County because (b) the real property that is the subject of this suit is located in this County.1 V. FACTS 4. On or about August 30, 2018, Harrison Major (“Mortgagor”) took out a Home Equity Loan (the “Loan”) secured by 524 Erikson Trail, Irving, 75060 (the “Property”), with the following legal description: Being Lot in Block “E” of Kensington Estates, an Addition to the City of Irving, Dallas County, Texas, according to the Map or Plat Thereof Recorded in Volume 78053, Page 2049 of the Map Records of Dallas County, Texas, Defendant is the current holder of the Loan. 5. On September 12, 2018, Bank of America prepared the Home Equity Line of Credit Security Instrument (the “Security”), which allegedly secured the Loan with the Property. 6. On or about November 9, 2020, the Mortgagor died. Pursuant to an Affidavit of Heirship recorded at Document No. 202000352962, in the Official Public Records of Dallas 1 Tex. Civ. Prac. & Rem. Code §15.011. PLAINTIFFS’ ORIGINAL PETITION Page 2 14404241v1 10257.058 County, Texas, the Mortgagor had one child, Jennifer Rasberry, and two stepchildren, Carrie Jo Dean and Tammie Lynn Williams. 7. Carrie Jo Dean and Tammie Lynn Williams possessed an interest in the Property and each subsequently deeded their interest to Jennifer Rasberry via a General Warranty Deed recorded on December 17, 2020 as Document No. 202000352963 in the Official Public Records of Dallas County, Texas. 8. Jennifer Rasberry then deeded the entire Property to SDal Holdings LLC (“SDal”) via a General Warranty Deed recorded on December 17, 2020 as Document No. 202000352964, in the Official Public Records of Dallas County, Texas. The title company utilized to close this transaction was Community National Title, LLC (“CNAT”). 9. At CNAT’s request and on November 23, 2020, Bank of America provided CNAT a payoff calculation for the Loan good through December 23, 2020 (the “Payoff Letter”). The Payoff Letter calculated the sum needed to pay off all indebtedness to be $58,819.55, and it is the only payoff quote that Bank of America ever issued in response to CNAT’s request for a complete payoff amount for the Loan. 10. On December 16, 2020, CNAT wired Bank of America $58,819.55 to pay off the Loan in accordance with the Payoff Letter. It is undisputed that CNAT’s payment was timely, that the payment was for the entire sum quoted by Bank of America, and that the payment was made pursuant to all terms of the Payoff Letter. It is Plaintiffs’ understanding that after this payment was made, Bank of America assigned its entire interest in the Loan to Defendant. 11. SDal next deeded the Property to Miguel A. Hernandez via a Special Warranty Deed recorded on December 18, 2020 as Document No. 202000354597, in the Official Public Records of Dallas County, Texas. PLAINTIFFS’ ORIGINAL PETITION Page 3 14404241v1 10257.058 12. Miguel A. Hernandez then deeded the Property to the Plaintiffs via a Warranty Deed with Vender’s Lien recorded on March 29, 2022 as Document No. 202200085985, in the Official Public Records of Dallas County, Texas. 13. Two and a half years after CNAT’s payment and in spite of the Loan being paid off in full, Defendant initiated an expedited judicial foreclosure proceeding against Plaintiffs under Texas Rules of Civil Procedure 735 and 736 on June 1, 2023 (the “736 Action”).2 In its application, Defendant averred that Plaintiffs – not the Mortgagor – were in default of the terms of the Loan because 30 regular monthly payments had not been paid. Defendant alleges that the total amount remaining to pay off the Loan is $41,189.57, but is unable to identify any evidence that the Loan was not satisfied in full by CNAT’s payment in accordance with the Payoff Letter on December 16, 2020. 14. A hearing for the 736 Action is set for April 25, 2024. VI. CAUSES OF ACTION A. Suit to Quiet Title 15. Plaintiffs reallege and incorporate all previous paragraphs as if fully set forth herein. 16. The elements for a suit to quiet title are: (a) an interest in a specific property, (b) title to the property is affected by a claim by the defendant, and (c) that the claim, although facially valid, is invalid or unenforceable. Vernon v. Perrien, 390 S.W.3d 47 (Tex. App. -- El Paso 2012, review denied). 17. Defendant claims the Security is their interest in the Property and argue that it forms the basis of the 736 Action and Defendant’s attempt to sell the Property at foreclosure auction. 2 Cause No. 096-348666-23, in the 96th District Court of Tarrant County, Texas. PLAINTIFFS’ ORIGINAL PETITION Page 4 14404241v1 10257.058 Plaintiffs’ title to the Property is affected by Defendant’s claim that it has a right to foreclose because the Loan was supposedly not paid off. However, the Security sought to be foreclosed is invalid or unenforceable because the Loan secured by the Property was paid off on December 16, 2020, pursuant to Bank of America’s Payoff Letter. 18. Defendant’s claim that the Loan has an outstanding balance of $41,189.57 and that it is entitled to foreclose on the Property constitutes a cloud and impediment on Plaintiffs’ title to the Property. Because the Loan has been satisfied, the Security and Defendant’s claim are each invalid. Plaintiffs request that title to the Property be quieted in favor of Plaintiffs, free and clear of the Loan, the Security, and all related security instruments or liens. B. Declaratory Judgment 19. Plaintiffs reallege and incorporate all previous paragraphs as if fully set forth herein. 20. Plaintiffs and Defendant have a justiciable controversy concerning whether (a) the Defendant has a present right to foreclose on the Property; and (b) whether all security for and liens arising from the Loan are valid and enforceable. 21. Defendant’s predecessor in interest issued the Payoff Letter to CNAT on November 23, 2020, stating that the remaining balance on the Security secured by the Property was $58,819.55, and requiring payment of that sum on or before December 23, 2020. It is undisputed that on December 16, 2020, and in accordance with the Payoff Letter, CNAT wired Defendant’s predecessor in interest the sum of $58,819.55. 22. By accepting an assignment of the Security and the Loan, Defendant stepped into the shoes of its predecessor in interest, and Defendant’s rights were therefore affected by CNAT’s PLAINTIFFS’ ORIGINAL PETITION Page 5 14404241v1 10257.058 payment. As a result, Plaintiffs seek a declaration that the Loan, the Security, and Defendant’s right to foreclose have been extinguished by CNAT’s satisfaction of the terms of the Payoff Letter. 23. In the alternative, Plaintiffs seek a declaration that Defendant is equitably estopped from enforcing the terms of the Loan, the Security, or their right to foreclose because on November 23, 2020, Defendant’s predecessor expressly represented that the sum of $58,819.55 was needed to pay off the Loan and discharge the Security. Defendant stepped into the shoes of its predecessor who made that representation, which was relied on by CNAT and the Plaintiffs to their detriment. Defendant is now estopped from claiming a different sum was needed to satisfy the Loan over and above the sum identified in the Payoff Letter to CNAT on November 23, 2020. 24. Therefore, Plaintiffs respectfully request this Court enter judgment declaring that Defendant is estopped from attempting to foreclose on the Property or otherwise claiming that it can enforce the terms of the Loan or the Security against Plaintiffs or the Property. D. Claim for Attorneys’ Fees and Costs 25. Plaintiffs request and are entitled to recovery of their reasonable and necessary attorney fees, expenses, and costs incurred in the prosecution of their claims herein pursuant to Texas Civil Practice and Remedies Code section 37.009. 26. Plaintiffs further seek recovery of pre and post judgment interest at the maximum amount permitted by Texas law. VII. STAY OF FORECLOSURE UNDER TEXAS RULE OF CIVIL PROCEDURE 736.11 27. Plaintiffs reallege and incorporate all previous paragraphs as if fully set forth herein. PLAINTIFFS’ ORIGINAL PETITION Page 6 14404241v1 10257.058 28. This lawsuit is a separate, original proceeding that puts into issue the enforcement of the loan agreement, contract, or lien sought to be foreclosed, specifically, the Security and the Loan. Therefore, pursuant to Texas Rule of Civil Procedure 736.11, the 736 Action must be automatically stayed through a trial on the merits of the captioned cause. VIII. PRAYER WHEREFORE PREMISES CONSIDERED, Plaintiffs pray that Defendant be cited to appear and answer and that, after final hearing or trial, the Court enter a judgment: a. Title to the Property is quieted in favor of Plaintiffs; b. Declaring that the Loan, the Security, and Defendant’s right to foreclose have been extinguished; c. Declaring that Defendant is estopped from attempting to foreclose on the Property or otherwise claiming that it can enforce the terms of the Loan or the Security against Plaintiffs or the Property, d. Awarding Plaintiffs their reasonable and necessary attorneys’ fees incurred in prosecuting Plaintiffs’ claims through trial and, if necessary, through appeal, plus costs of court, and e. Awarding Plaintiffs such other relief, at law or in equity, to which Plaintiffs may be justly entitled. PLAINTIFFS’ ORIGINAL PETITION Page 7 14404241v1 10257.058 Respectfully submitted, THOMPSON, COE, COUSINS & IRONS, L.L.P. By: /s/ Matt R. Daigle . Craig L. Dowis State Bar No. 24043743 cdowis@thompsoncoe.com Matt R. Daigle State Bar No. 24043743 mdaigle@thompsoncoe.com Kayla F. Aitken State Bar No. 24115429 kaitken@thompsoncoe.com Plaza of the Americas 700 N. Pearl Street, Twenty-Fifth Floor Dallas, TX 75201-2832 Telephone: (214) 871-8200 Facsimile: (214) 871-8209 ATTORNEYS FOR PLAINTIFFS PLAINTIFFS’ ORIGINAL PETITION Page 8 14404241v1 10257.058 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. Megan Mantas on behalf of Craig Dowis Bar No. 24028655 MMantas@thompsoncoe.com Envelope ID: 86866084 Filing Code Description: Original Petition Filing Description: Status as of 4/24/2024 3:31 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Craig Dowis cdowis@thompsoncoe.com 4/19/2024 2:24:43 PM SENT Megan Mantas mmantas@thompsoncoe.com 4/19/2024 2:24:43 PM SENT Vivian Demianiw vdemianiw@thompsoncoe.com 4/19/2024 2:24:43 PM SENT Matt Daigle mdaigle@thompsoncoe.com 4/19/2024 2:24:43 PM SENT