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  • LEZLIE A. JOHNSTON  vs.  LINCOLN PROPERTY COMPANY MANAGEMENT, INC., et alPROPERTY document preview
  • LEZLIE A. JOHNSTON  vs.  LINCOLN PROPERTY COMPANY MANAGEMENT, INC., et alPROPERTY document preview
  • LEZLIE A. JOHNSTON  vs.  LINCOLN PROPERTY COMPANY MANAGEMENT, INC., et alPROPERTY document preview
						
                                

Preview

CAUSE NO. 07145 LEZLIE A. JOHNSTON IN THE DISTRICT COURT Plaintiff, JUDICIAL DISTRICT LINCOLN PROPERTY COMPANY MANAGEMENT, INC., LINCOLN PROPERTY COMPANY, LINCOLN PROPERTY COMPANY COMMERCIAL, INC. and LOCH ENERGY SQUARE LP Defendants. DALLAS COUNTY, TEXAS AGREED MOTION TO CHANGE CAPTION OF THE CASE NOW COMES, Lezlie Johnston, Plaintiff, respectfully requests the Court to change the style and caption of the above mentioned case to add Lincoln Property Company Commercial, Inc. and Loch Energy Square LP as further named Defendants and in support would respectfully show the Court as follows: 1. This case was filed on June 14, 2016, naming Lincoln Property Company Management, Inc. and Lincoln Property Company as Defendants. 2. On August 1, 2016, Defendants Lincoln Property Company Management, Inc. and Lincoln Property Company filed their Original Answer to Plaintiff’s Original Petition. 3. On September 14, 2016, this Honorable Court signed an Order substituting Stephen R. Marsh as Defendants Lincoln Property Company Management, Inc. and Lincoln Property Company counsel of record. 4. On November 17, 2016, Defendant Lincoln Property Company Commercial, Inc. filed its Original Answer and General Denial. 5. On November 22, 2016, Plaintiff filed her First Amended Petition naming Lincoln Agreed Motion to Change Caption of the Case Property Company Commercial, Inc. and Loch energy Square LP as additional Defendants. On December 13, 2016, Defendant Loch Energy Square LP filed its Original Answer and General Denial. Both Defendants Lincoln Property Company Commercial, Inc. and Loch Energy Square LP have filed answers making an appearance and are before this Honorable Court. Respectfully submitted, /s/ Kolter R. Jennings Kolter R. Jennings SBN 24094048 Kolter@pulshaney.com Mark A. Haney 08908480 Mark@pulshaney.com Kelly Puls SBN 07455200 Kelly@pulshaney.com ULS ANEY PLLC OMMERCE TREET UITE ORT ORTH EXAS 76102 ELEPHONE 1717 ACSIMILE 1333 ATTORNEYS FOR PLAINTIFF Agreed Motion to Change Caption of the Case CERTIFICATE CONFERENCE Kolter R. Jennings, hereby certify that on September 26, 2017, conferenced with Defendants counsel, Stephen Marsh, via email and that Defendants agree to the above Motion and Proposed Order granting same. /s/ Kolter R. Jennings Kolter R. Jennings ERTIFICATE OF ERVICE This is to certify that a true and correct copy of the foregoing Agreed Motion To Change Caption of The Case has been forwarded to Defendant, by and through its attorney of record, as listed below, via email, on this 27 day of September, 2017. STEPHEN R. MARSH Texas Bar No. 13019700 1301 E. Collins Blvd., Suite 490 Richardson, TX Direct Telephone: 570 Telephone: 214 6300 Facsimile: 214 6262 Email: smarsh@travelers.com ATTORNEYS FOR DEFENDANTS /s/ Kolter R. Jennings Kolter R. Jennings Agreed Motion to Change Caption of the Case