On November 01, 2019 a
Request,Application
was filed
involving a dispute between
De Man, Patrick A P,
and
Aspire Commodities L P,
Raiden Commodities L P,
for Foreign Judgment
in the District Court of Harris County.
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CAUSE NO. 2019-79857
ATRICK A.P. D IN THE DISTRICT COURT OF
HARRIS COUNTY, TEXAS
RAIDEN COMMODITIES, L.P., and 61ST JUDICIAL DISTRICT
SPIRE COMMODITIES, L.P.
AMENDED REQUEST FOR AND NOTICE OF SUBMISSION
Raiden Commodities, L.P. and Aspire Commodities, L.P. (“Judgment Debtors”) filed their
Motion to Vacate the Attempted Domestication of Foreign Judgment, and in the Alternative,
Request for Clarification Regarding Payment (the “Motion”), on December 16, 2019. Judgment
Debtors set the Motion for oral hearing on March 19, 2020, and to date they have filed three
amended hearing notices, which in aggregate have pushed the oral hearing date to August 13,
2020, nearly eight (8) months beyond the date the Motion was originally filed.
As explained more fully in Mr. De Man’s response to the Motion, led on May 29, 2020
the Motion should be denied because the Court lacks jurisdiction to hear it and because Judgment
Debtors have presented no evidence in the Motion to meet their burden of proof. Accordingly,
under either/both bases, an oral hearing is not necessary to decide the Motion. For expedient
resolution of the Motion, Patrick A.P. De Man hereby requests that the Motion be set on the Court’s
submission docket for Monday, July 27 at 8:00 a.m. in the 61st Judicial District Court of
Harris County, Texas.
Respectfully submitted,
EYNOLDS RIZZELL LLP
By: /s/ Chris Reynolds
Chris Reynolds
Texas Bar No. 16801900
Matthew Sheehan
Texas Bar No.
1100 Louisiana Street, Suite 3500
Houston, Texas 77002
Telephone: (713) 485 7200
Facsimile: (713) 485 7250
creynolds@reynoldsfrizzell.com
msheehan@reynoldsfrizzell.com
ATTORNEYS FOR
PATRICK A.P. DE MAN
CERTIFICATE OF SERVICE
I certify that on this th day of July, , a true and correct copy of the foregoing instrument
has been served upon all known counsel of record in accordance with the requirements of the Texas Rules
of Civil Procedure, by electronic e filing service provider and/or electronic mail
/s/ Chris Reynolds
Chris Reynolds
Document Filed Date
July 15, 2020
Case Filing Date
November 01, 2019
Category
Foreign Judgment
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CAUSE NO. 2019-79857 ATRICK A.P. D IN THE DISTRICT COURT OF HARRIS COUNTY, TEXAS RAIDEN COMMODITIES, L.P., and 61ST JUDICIAL DISTRICT SPIRE COMMODITIES, L.P. AMENDED REQUEST FOR AND NOTICE OF SUBMISSION Raiden Commodities, L.P. and Aspire Commodities, L.P. (“Judgment Debtors”) filed their Motion to Vacate the Attempted Domestication of Foreign Judgment, and in the Alternative, Request for Clarification Regarding Payment (the “Motion”), on December 16, 2019. Judgment Debtors set the Motion for oral hearing on March 19, 2020, and to date they have filed three amended hearing notices, which in aggregate have pushed the oral hearing date to August 13, 2020, nearly eight (8) months beyond the date the Motion was originally filed. As explained more fully in Mr. De Man’s response to the Motion, led on May 29, 2020 the Motion should be denied because the Court lacks jurisdiction to hear it and because Judgment Debtors have presented no evidence in the Motion to meet their burden of proof. Accordingly, under either/both bases, an oral hearing is not necessary to decide the Motion. For expedient resolution of the Motion, Patrick A.P. De Man hereby requests that the Motion be set on the Court’s submission docket for Monday, July 27 at 8:00 a.m. in the 61st Judicial District Court of Harris County, Texas. Respectfully submitted, EYNOLDS RIZZELL LLP By: /s/ Chris Reynolds Chris Reynolds Texas Bar No. 16801900 Matthew Sheehan Texas Bar No. 1100 Louisiana Street, Suite 3500 Houston, Texas 77002 Telephone: (713) 485 7200 Facsimile: (713) 485 7250 creynolds@reynoldsfrizzell.com msheehan@reynoldsfrizzell.com ATTORNEYS FOR PATRICK A.P. DE MAN CERTIFICATE OF SERVICE I certify that on this th day of July, , a true and correct copy of the foregoing instrument has been served upon all known counsel of record in accordance with the requirements of the Texas Rules of Civil Procedure, by electronic e filing service provider and/or electronic mail /s/ Chris Reynolds Chris Reynolds