On December 22, 2011 a Letter,Correspondence was filed involving a dispute between Harris County Texas, and International Paper Company, Mcginnes Industrial Maintenance Corporation, Waste Management Inc, Waste Management Of Texas Inc, for OTHER CIVIL in the District Court of Harris County.
August 26, 2013
December 22, 2011
OTHER CIVIL
Disposed (Final)
201176724, INTERNATIONAL PAPER COMPANY BY Registered Agent
Attorney Name Attorney
BAKER, DEBRA TSUCHIYAMA Attorney for the Plaintiff
BALLARD, GLENN ARLEN JR. Attorney
HARRIS COUNTY TEXAS Cross Defendant
HARRIS COUNTY TEXAS Plaintiff
HINTON, PAULA WEEMS Attorney
HINTON, PAULA WEEMS Attorney for the Defendant
INTERNATIONAL PAPER COMPANY BY SERVING ITS REGISTERED AGENT CT Registered Agent
INTERNATIONAL PAPER COMPANY (SUCCESSOR TO CHAMPION PAPERS INC) Cross Plaintiff
INTERNATIONAL PAPER COMPANY (SUCCESSOR TO CHAMPION PAPERS INC) Defendant
MCGINNES INDUSTRIAL MAINTENANCE CORPORATION Cross Plaintiff
MCGINNES INDUSTRIAL MAINTENANCE CORPORATION Defendant
MCGINNES INDUSTRIAL MAINTENANCE CORPORATION BY SERVING ITS REGISTERED Registered Agent
NELSON, DANIEL W. Pro Hac Vice Attorney
OWENS, ROCK WILLIAM A. Attorney
PARKER, JOHN D. Pro Hac Vice Attorney
REASONER, BARRETT H. Attorney
REASONER, BARRETT H. Attorney for the Defendant
SCHRADER, DAVID L. Pro Hac Vice Attorney
SMITH, MARY ELIZABETH Attorney
STANFIELD, CRAIG ANDREW Attorney
STANFIELD, CRAIG ANDREW Attorney for the Defendant
THE STATE OF TEXAS (ACTING BY AND THROUGH THE TEXAS COMMISSION ON Registered Agent
THE STATE OF TEXAS ACTING BY AND THROUGH THE TEXAS COMMISSION ON Cross Defendant
WASTE MANAGEMENT INC Cross Plaintiff
WASTE MANAGEMENT INC Defendant
WASTE MANAGEMENT INC BY SERVING ITS REGISTERED AGENT CT CORPORATION Registered Agent
WASTE MANAGEMENT OF TEXAS INC Cross Plaintiff
WASTE MANAGEMENT OF TEXAS INC Defendant
WASTE MANAGEMENT OF TEXAS INC BY SERVING ITS REGISTERED AGENT CT Registered Agent
ZWANG-WEISSMAN, YARDENA R. Pro Hac Vice Attorney
Winstol Carter Attorney
Dale Trimble Attorneys for Plaintiffs
Anthony Benedict Attorney
Earnest Wotring Attorneys for Plaintiffs
Matthew Caligur Attorneys for Defendants
Joshua Thomas Attorneys for Defendants
Allyson Ho Attorney
Christopher Dodson Attorney
Kevin Nunnally Attorney
John Riley Attorney
Thomas Hutcheson Attorney
Albert Axe Attorneys for Defendants
Michael Connelly Attorneys for Plaintiffs
John Muir Attorneys for Plaintiffs
William George Attorneys for Plaintiffs
Michael Perrin Attorney
John Na Attorneys for Plaintiffs
J. Hill Attorney
Ba Nguyen Attorney
Brent Coon Attorney
Minh-Tam Tran Attorneys for Defendants
Tuananh Mai Attorneys for Defendants
Ryan Nguyen Attorneys for Plaintiffs
Bill Cox Attorney
Paul Sarahan Attorney
Linda Secord Attorney
Peter Nolan Attorney
Bruce Wilkin Attorney
Jennifer Nelsen Attorney
Renee Wilkerson Attorney
William Collins Attorney
Melanie Gray Attorney
Robin Gibbs Attorney
Sydney Ballesteros Attorneys for Defendants
Tracy Penn Attorneys for Defendants
Emily Petrick Attorney
Marilyn Vilandos Attorneys for Plaintiffs
Vincent Ryan Attorney
Tommie Thornhill Attorney
Anthony Kaim Attorneys for Defendants
Colin Pogge Attorneys for Defendants
Craig Pritzlaff Attorney
Ekaterina DeAngelo Attorney
Mark Giugliano Attorneys for Defendants
Walter Berger Attorney
James Moore Attorneys for Defendants
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BRACEWELL Texas New York Washington, DC Glenn A. Ballard Jr. Partner, Trial Section Head &GIULIANI Connecticut 713.221.1454 Office 713.222.3000 Fax a Dubai London Glenn.Ballard@bgllp.com Bracewell & Giuliani LLP FILED 711 Louisiana Street Suite 2300 Chris Daniel Houston, Texas 77002-2770 District Clerk Board Certified, Civil Trial Law AUG 26 2013 Texas Board of Legal Specializationp. 5 Tit ime: By Via E-Filing and Hand Delivery Mr. Jay Hicks, Clerk 295" Judicial District Court of Harris County, Texas 201 Caroline, 14" Floor Houston, Texas 77002 Re: Consolidated Case No. 2011-76724; Harris County, Texas and the State of Texas v. International Paper Co., et al; In the 295" District Court of Harris County, Texas; Cause No. 2012-58016; Dao Van Pho, et al v. International Paper Co., et al; In the 151 Judicial District, Harris County, Texas Cause No. 2012-66308; Jim Harpster and Jennifer Harpster, et al. v. Int'l Paper Co., et al.; In the 11" Judicial District Court of Harris County, Texas Dear Mr. Hicks: Attached is an email string constituting a Rule 11 Agreement between counsel for plaintiffs and counsel for defendants in the Pho matter. Both parties have agreed that the Pho Plaintiffs’ Motion to Set Aside Order of Consolidation should be set for hearing with Judge Baker on September 16, 2013 or as soon thereafter as the Court can conduct such a hearing. As directed by the Court, the defendants will be filing their responses to this motion by August 28, 2013. Thank you for your assistance in this matter. Very truly yours, Braceweif Giuliani LLP Z; of ' Ballard Jr. GAB/ec Enclosure BRACEWELL &GIULIANI —_—_ a Mr. Jay Hicks, Clerk August 26, 2013 Page 2 cc. Mr. Michael W. Perrin, PLLC 2323 South Shepherd 14th Floor Houston, Texas 77019 Michael Connelly Debra Tsuchiyama Baker Earnest Wotring CONNELLY BAKER WOTRING LLP 700 JPMorgan Chase Tower 600 Travis Street Houston, Texas 77002 Matthew W. Caligur BAKER HOSTETLER LLP 1000 Louisiana Street, Ste. 2000 Houston, Texas 77002 Rock W.A. Owens OFFICE OF HARRIS COUNTY ATTORNEY 1019 Congress, Room 1547 Houston, Texas 77002 Dale L. Trimble THE TRIMBLE FIRM PLLC 209 Simonton Conroe, Texas 77301 Mary E. Smith OFFICE OF THE ATTORNEY GENERAL OF TEXAS P.O. Box 12548, Capitol Station Austin, Texas 78711 Thomas T. Hutcheson Albert R. Axe WINSTEAD PC 1100 JP Morgan Chase Tower 600 Travis Street Houston, Texas 77002 #4358027.1 Ballard, Glenn ss From: Ballard, Glenn Sent: Monday, August 26, 2013 3:01 PM To: ‘Michael W. Perrin’ Ce: ttran@tt-lawfirm.com; Marc Hill; pmai@tt-lawfirm.com; jna@tt-lawfirm.com; Riley, John; Dodson, Chris; Nunnally, Knox Subject: RE: Rule 11 Agreement regarding Interrogatories & Hearing Date Agreed. Glenn A. Ballard, Jr. | Partner | Trial Section Head | Bracewell & Giuliani LLP 711 Louisiana Street, Suite 2300 | Houston, Texas | 77002-2770 T: 713.221.1454 | F: 713.222.3000 glenn.ballard@bgllp.com | www.bgllp.com/ballard | www.bgllp.com CONFIDENTIALITY STATEMENT This message is sent by a law firm and may contain information that is privileged or confidential. If you received this transmission in error, please notify the sender by reply e-mail and delete the message and any attachments. From: Michael W. Perrin [mailto:mperrin@ohdlegal.com: Sent: Monday, August 26, 2013 2:00 PM To: Ballard, Glenn Ce: ttran@tt-lawfirm.com; Marc Hill; pmai@tt-lawfirm.com; jna@tt-lawfirm.com; Riley, John; Dodson, Chris; Nunnally, Knox Subject: Rule 11 Agreement regarding Interrogatories & Hearing Date Mr. Glenn Ballard Bracewell & Guiliani Dear Glenn: This email is to confirm our rule 11 agreement to: 1) extend the deadline to respond to Interrogatories served by Waste Management of Texas, Inc. on July 30 by three weeks from August 29, 2013 to September 19, 2013; and 2) agree to a hearing date of September 16, 2013 for the Motion to Set Aside Consolidation Order. In the event that Judge Baker does not have that date available for a hearing, we mutually agree to a hearing on that Motion at the earliest date after September 16. Your earlier email was on behalf of Waste Management, Inc. whereas the Interrogatories served on the Pho Plaintiffs came from Waste Management of Texas, Inc. I do not believe this instant email changes the gist of our discussion. Please advise if this accurately reflects our agreement. 1 Thank you, Mike Perrin Michael W. Perrin, PLLC 2323 South Shepherd 14" Floor Houston, Texas 77019 713-979-4478 michaelwperrin@gmail.com SS From: Michael W. Perrin Sent: Monday, August 26, 2013 11:44 AM To: Ballard, Glenn Ce: Nunnally, Knox; Dodson, Chris; Riley, John; ttran@tt-lawfirm.com; Marc Hill; pmai@tt- lawfirm.com;, jna@tt-lawfirm.com; Tegan Baker Subject: RE: Consolidated Cause No. 2012-58016; Pho, et. al. v. International Paper Company, et. al. Confirmed-I have learned | have been called for Jury Duty on Wednesday September 18. That should not be a problem regarding the hearing, unless that is the only date Judge Baker has. Mike Perrin From: Ballard, Glenn [mailto:Glenn.Ballard@ballp.com] Sent: Monday, August 26, 2013 11:36 AM To: ichael W. Perrin Cc: junnally, Knox; Dodson, Chris; Riley, John Subject: Consolidated Cause No. 2012-58016; Pho, et. al. v. International Paper Company, et. al. Mike, good to talk to you just now. Per your request, we have agreed to allow the Pho Plaintiffs three additional weeks to respond to Waste Management, Inc.’s First Set of Interrogatories to the Pho Plaintiffs, which will make your answers due on Wednesday September 18, 2013, and we have further agreed to have a hearing on The Pho Plaintiffs’ Motion to Set Aside Order of Consolidation for Pretrial Discovery in Judge Baker’s Court on September 16, 2013, or if the Court is not available on that date then the first available date for the Court after that date. Thanks for your attention to this matter. Glenn A. Ballard, Jr. | Partner | Trial Section Head | Bracewell & Giuliani LLP 711 Louisiana Street, Suite 2300 | Houston, Texas | 77002-2770 T: 713.221.1454 | F: 713.222.3000 glenn.ballard@bgllp.com | www.bgllp.com/ballard | www.bgllp.com CONFIDENTIALITY STATEMENT This message is sent by a law firm and may contain information that is privileged or confidential. If you received this transmission in error, please notify the sender by reply e-mail and delete the message and any attachments.