On December 27, 2018 a
Louise Margaret Mckenzie and Donald Colin Mckenzie's Supplemental Response Supporting Award of Attor - Motion (No Fee)
was filed
involving a dispute between
Vinet, Terra,
and
Mckenzie, Colin Donald,
Mckenzie, Louise Margaret,
for Inj/Damage-Other Injury or Damage >$200,000
in the District Court of Montgomery County.
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Received and E-Filed for Record
8/27/2019 4:17 PM
Melisa Miller, District Clerk
Montgomery County, Texas
Deputy Clerk, Megan Shiflett
CAUSE NO. 18-12-16948
TERRA VINET § IN THE DISTRICT COURT OF
Plaintiff, §
§
vs. § MONTGOMERY COUNTY, TEXAS
§
LOUISE MARGARET MCKENZIE §
AND COLIN DONALD MCKENZIE §
Defendants. § 284th JUDICIAL DISTRICT
LOUISE MARGARET MCKENZIE AND DONALD COLIN MCKENZIE’S
SUPPLEMENTAL RESPONSE SUPPORTING AWARD OF ATTORNEY FEES
TO THE HONORABLE JUDGE OF THIS COURT:
COME NOW, Defendants/Counter-Plaintiffs, LOUISE MARGARET MCKENZIE and
COLIN DONALD MCKENZIE (collectively, “Defendants” or “McKenzies”), and file LOUISE
MARGARET MCKENZIE and COLIN DONALD MCKENZIE’s Supplemental Response
Supporting Award of Attorney Fees brought in response to TERRA VINET’s Motion to Dismiss
Counterclaims brought under the TEXAS CITIZENS PARTICIPATION ACT, codified in Chapter 27 of
the TEXAS CIVIL PRACTICES & REMEDIES CODE. In support thereof, the McKenzies respectfully
show the following unto the Court:
WHEREAS, this Honorable Court denied Terra Vinet’s Motion to Dismiss Counterclaims
allegedly brought under the TEXAS CITIZENS PARTICIPATION ACT.
WHEREAS, this Honorable Court has determined that Louise and Colin McKenzie are
entitled to recover their reasonable attorney’s fees and court courts to be determined by submission
to the Court.
WHEREAS, by way of this filing, Louise and Colin McKenzie hereby present their
evidence of attorney fees and costs and seek an award of $17,611.
Page 1 of 2
I.
EVIDENCE
(1) Exhibit “A” Attorney Fee affidavit of Richard Weaver
(2) Exhibit “A-1 Attorney Fee invoices.
II.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Defendants/Counter-Plaintiffs, LOUISE
MARGARET MCKENZIE and COLIN DONALD MCKENZIE, respectfully request the Court
enter the attached Order awarding Defendants/Counter-Plaintiffs, LOUISE MARGARET
MCKENZIE and COLIN DONALD MCKENZIE, court costs and reasonable attorney’s fees in
the amount of $17,611.
Respectfully submitted,
THE WEAVER LAW FIRM
/s/ Richard D. Weaver
Richard D. Weaver
Texas Bar No. 24047083
rweaver@weaverlawyers.com
James Hamilton Foley
Texas Bar No. 24059764
jfoley@weaverlawyers.com
1800 Bering Drive, Suite 1050
Houston, Texas 77057
(713) 572-4900 (Telephone)
(713) 513-5566 (Facsimile)
ATTORNEYS FOR LOUISE
MARGARET MCKENZIE and
COLIN DONALD MCKENZIE
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was forwarded to all interested
parties by service on their attorneys of record via email on August 27, 2019, as follows:
Brad Beers Via E-mail: BBeers@BeersLaw.net
BEERS LAW FIRM
5020 Montrose Blvd., Suite 700
Houston, Texas 77006
/s/ Richard D. Weaver
Page 2 of 2
Document Filed Date
August 27, 2019
Case Filing Date
December 27, 2018
Category
Inj/Damage-Other Injury or Damage >$200,000
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Received and E-Filed for Record 8/27/2019 4:17 PM Melisa Miller, District Clerk Montgomery County, Texas Deputy Clerk, Megan Shiflett CAUSE NO. 18-12-16948 TERRA VINET § IN THE DISTRICT COURT OF Plaintiff, § § vs. § MONTGOMERY COUNTY, TEXAS § LOUISE MARGARET MCKENZIE § AND COLIN DONALD MCKENZIE § Defendants. § 284th JUDICIAL DISTRICT LOUISE MARGARET MCKENZIE AND DONALD COLIN MCKENZIE’S SUPPLEMENTAL RESPONSE SUPPORTING AWARD OF ATTORNEY FEES TO THE HONORABLE JUDGE OF THIS COURT: COME NOW, Defendants/Counter-Plaintiffs, LOUISE MARGARET MCKENZIE and COLIN DONALD MCKENZIE (collectively, “Defendants” or “McKenzies”), and file LOUISE MARGARET MCKENZIE and COLIN DONALD MCKENZIE’s Supplemental Response Supporting Award of Attorney Fees brought in response to TERRA VINET’s Motion to Dismiss Counterclaims brought under the TEXAS CITIZENS PARTICIPATION ACT, codified in Chapter 27 of the TEXAS CIVIL PRACTICES & REMEDIES CODE. In support thereof, the McKenzies respectfully show the following unto the Court: WHEREAS, this Honorable Court denied Terra Vinet’s Motion to Dismiss Counterclaims allegedly brought under the TEXAS CITIZENS PARTICIPATION ACT. WHEREAS, this Honorable Court has determined that Louise and Colin McKenzie are entitled to recover their reasonable attorney’s fees and court courts to be determined by submission to the Court. WHEREAS, by way of this filing, Louise and Colin McKenzie hereby present their evidence of attorney fees and costs and seek an award of $17,611. Page 1 of 2 I. EVIDENCE (1) Exhibit “A” Attorney Fee affidavit of Richard Weaver (2) Exhibit “A-1 Attorney Fee invoices. II. PRAYER WHEREFORE, PREMISES CONSIDERED, Defendants/Counter-Plaintiffs, LOUISE MARGARET MCKENZIE and COLIN DONALD MCKENZIE, respectfully request the Court enter the attached Order awarding Defendants/Counter-Plaintiffs, LOUISE MARGARET MCKENZIE and COLIN DONALD MCKENZIE, court costs and reasonable attorney’s fees in the amount of $17,611. Respectfully submitted, THE WEAVER LAW FIRM /s/ Richard D. Weaver Richard D. Weaver Texas Bar No. 24047083 rweaver@weaverlawyers.com James Hamilton Foley Texas Bar No. 24059764 jfoley@weaverlawyers.com 1800 Bering Drive, Suite 1050 Houston, Texas 77057 (713) 572-4900 (Telephone) (713) 513-5566 (Facsimile) ATTORNEYS FOR LOUISE MARGARET MCKENZIE and COLIN DONALD MCKENZIE CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was forwarded to all interested parties by service on their attorneys of record via email on August 27, 2019, as follows: Brad Beers Via E-mail: BBeers@BeersLaw.net BEERS LAW FIRM 5020 Montrose Blvd., Suite 700 Houston, Texas 77006 /s/ Richard D. Weaver Page 2 of 2