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RECEIVER’S SUPPORTING EXHIBITS FOR HIS RESPONSE TO
TRACI GRAHAM’S MOTION FOR SUMMARY JUDGMENT
HE ONORABLE OURT
The following exhibits are submitted in support of, and incorporated by reference
ee
Seth Kretzer, Receiver, v. Traci Rose GrahamNo.
Receiver’s Supporting Exhibits for his Response to Traci Graham’s Motion for Summary Judgment Page
Documents of Platinum Title Partners, LLC
on 1517 Cunningham Parc Lane, Todd &
Traci Graham
Copies of checks written to Cunningham
Development on Graham business account
Uniform Residential Loan Application, First
United Bank and Trust Company signed by
Todd and Traci Graham.
Fidelity Investment monthly statements of
Todd Graham and Graham Family
Partnership I, LP, 2017 to 2019, with
ness records affidavit, filed in no. 2019
98 on or about July 29, 202
incorporated herein by reference because
volume of exhib
Abstract of Judgment in Case No. 2015
33079, POB v. Todd Graham
Receivership appointment order in Case No.
33079, POB v. Todd Graham.
Business Records of Platinum Title with
Business Records Affidavit, Sections 1
Business Records of First United Bank with
Business Records Affidavit, Sections 1
Chart of shell companies created by Todd
and Traci Graham
Chart of network of shell companies created
by Todd and Traci Graham.
Fidelity Investment monthly statement
records for Graham Family Partnership I,
January 2017 Fidelity Investment monthly
statement records for Graham Family
Partnership I, LP. (Shows balance of
January 2018 Fidelity Investment monthly
statement records for Graham Family
Partnership I, LP. (Shows balance of
January 2019 Fidelity Investment monthly
statement records for Graham Family
Seth Kretzer, Receiver, v. Traci Rose Graham No.
Receiver’s Supporting Exhibits for his Response to Traci Graham’s Motion for Summary Judgment Page
Partnership I, LP. (Shows balance of only
July 2017 Fidelity Investment monthly
statement records for Graham Family
Partnership I, LP. (shows
Fidelity Investments check 1049, Graham
Family Partnership I, LP. To Cunningham
Development, $25,000
signed by Traci Graham.
Fidelity Investments check 1052, Graham
Family Partnership I, LP. To Cunningham
Development, $5,124.40, February 28, 2017,
signed by Traci Graham.
Fidelity Investments check 1056, Graham
Family Partnership I, LP. To Cunningham
Development, $14,539.21, April 10, 2017,
signed by Traci Graham, with hand written
change order note.
Fidelity Investments check 1057, Graham
Family Partnership I, LP. To Cunningham
Development,
signed by Traci Graham.
Fidelity Investments check 1060, Graham
Family Partnership I, LP. To Cunningham
Development, $12,792.36, June 1, 2017,
signed by Traci Graham.
Fidelity Investments check 1062, Graham
Family Partnership I, LP. To Cunningham
Development, $4,574.00, June 27, 2017,
signed by Traci Graham.
Email by Todd Graham June 20, 2017 to
Amy Scobee at First Federal. (“paid directly
Business records of Bank of America, March
Business records of JP Morgan Chase, April
Seth Kretzer, Receiver, v. Traci Rose Graham No.
Receiver’s Supporting Exhibits for his Response to Traci Graham’s Motion for Summary Judgment Page
Secretary of State Records for SuperOx
Holdings, LLC
Secretary of State Records for First Third
Capital Management, LLC
Secretary of State Records for First Third
Capital Partners II, LLC
Secretary of State Records for FIT
Management, LLC
Secretary of State Records for
Family Partnership I, LP
Secretary of State Records for MHT Partners
Secretary of State Records for MHT Partners
Management Company, LLC.
Texas Secretary of State list of entities
created by Todd Graham and Traci Graham.
Russell Abshire, Post Oak Bank affidavit,
Russell Abshire, Post Oak Bank declaration,
Promissory Note in the original principal
sum of $758,906.09 (the “SuperOx Note”).
(See Russell Abshire declaration.)
August 14, 2013 Commercial Guaranty
agreement to pay Post Oak Bank the
indebtedness of SuperOx (the “Graham
Guaranty”). (See Russell Abshire
declaration.)
U.S. Federal Income Tax Returns
Form 1040s submitted to Post Oak Bank for
the years 2010 to 2012 (See Russell Abshire
declaration.)
Graham balance sheet dated December 10,
2013 and a balance sheet dated June 30,
submitted to Post Oak Bank. (See
Russell Abshire declaration.)
August 26, 2014 Post Oak Bank Promissory
Note to the Graham Family Partnership I,
LP $1,317,500. (See Russell Abshire
declaration.)
Declaration of Charles H. Carmouche, Post.
Seth Kretzer, Receiver, v. Traci Rose Graham No.
Receiver’s Supporting Exhibits for his Response to Traci Graham’s Motion for Summary Judgment Page
Oak Bank, now Allegiance Bank, July
Post Oak Bank Release of
Lien
Declaration of Mr. Robert Kruckemeyer,
attorney for Post Oak Bank, now Allegiance
Letter of February 12, 2016, Manfred
Sternberg, Graham’s attorney
February 2016 Quitclaim Deed whereby
Graham and Traci conveyed ownership of
the Burkhardt Residence back to
Family Partnership
February 2016 Request to Remove
Homestead Exemption for filing with the
Harris County Appraisal District removing
the homestead exemption from the
Burkhardt Residence.
Affidavit of Seth Kretzer, Receiver. File
separately, incorporated by reference into
MSJ response and this list of exhibits.)
Respectfully submitted day of
th Kiger
ETH RETZER
RETZER OLBERDING
The Lyric Center
440 Louisiana, Ste. 1440
Houston, TX 77002
(713) 775 3050 (office)
Email: seth@kretzerfirm.com
ECEIVER
Seth Kretzer, Receiver, v. Traci Rose Graham No.
Receiver’s Supporting Exhibits for his Response to Traci Graham’s Motion for Summary Judgment Page
Samos Wi Velberding
By:
JAMES W. VOLBERDING
RETZER OLBERDING
Plaza Tower
110 North College Avenue
Suite 1850
Tyler, Texas 75702
(903) 597 6622 (Office)
(866) 398 6883 (Fax)
email: jamesvolberding@gmail.com
TTORNEY FOR ECEIVER
ERTIFICATE OF _ERVICE
I hereby certify that a true and correct copy of this document has been
delivered this ay of by electronic filing) to:
Shawn R. McKee
Casey Jon Lambright
Lambright Mckee
940 Corbindale Rd.
Houston, Texas 77024
(713) 840
(713) 840 fax
cjl@lambrightlaw.com
srm@lambrightlaw.com
My. Todd D. Graham
by the following means:
By USS. Postal Service Certified Mail, R.R.R.
By First Class U.S. Mail to Mr. Graham
By Special Courier
By Hand Delivery at hearing.
Seth Kretzer, Receiver, v. Traci Rose Graham No.
Receiver’s Supporting Exhibits for his Response to Traci Graham’s Motion for Summary Judgment Page
By Fax before
By Fax after
email to
By email with PDF
— __ filing service. ¢/ th Tirtger
SETH KRETZER
Seth Kretzer, Receiver, v. Traci Rose Graham No.
Receiver’s Supporting Exhibits for his Response to Traci Graham’s Motion for Summary Judgment Page
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RECEIVER’S SUPPORTING EXHIBITS FOR HIS RESPONSE TO TRACI GRAHAM’S MOTION FOR SUMMARY JUDGMENT HE ONORABLE OURT The following exhibits are submitted in support of, and incorporated by reference ee Seth Kretzer, Receiver, v. Traci Rose GrahamNo. Receiver’s Supporting Exhibits for his Response to Traci Graham’s Motion for Summary Judgment Page Documents of Platinum Title Partners, LLC on 1517 Cunningham Parc Lane, Todd & Traci Graham Copies of checks written to Cunningham Development on Graham business account Uniform Residential Loan Application, First United Bank and Trust Company signed by Todd and Traci Graham. Fidelity Investment monthly statements of Todd Graham and Graham Family Partnership I, LP, 2017 to 2019, with ness records affidavit, filed in no. 2019 98 on or about July 29, 202 incorporated herein by reference because volume of exhib Abstract of Judgment in Case No. 2015 33079, POB v. Todd Graham Receivership appointment order in Case No. 33079, POB v. Todd Graham. Business Records of Platinum Title with Business Records Affidavit, Sections 1 Business Records of First United Bank with Business Records Affidavit, Sections 1 Chart of shell companies created by Todd and Traci Graham Chart of network of shell companies created by Todd and Traci Graham. Fidelity Investment monthly statement records for Graham Family Partnership I, January 2017 Fidelity Investment monthly statement records for Graham Family Partnership I, LP. (Shows balance of January 2018 Fidelity Investment monthly statement records for Graham Family Partnership I, LP. (Shows balance of January 2019 Fidelity Investment monthly statement records for Graham Family Seth Kretzer, Receiver, v. Traci Rose Graham No. Receiver’s Supporting Exhibits for his Response to Traci Graham’s Motion for Summary Judgment Page Partnership I, LP. (Shows balance of only July 2017 Fidelity Investment monthly statement records for Graham Family Partnership I, LP. (shows Fidelity Investments check 1049, Graham Family Partnership I, LP. To Cunningham Development, $25,000 signed by Traci Graham. Fidelity Investments check 1052, Graham Family Partnership I, LP. To Cunningham Development, $5,124.40, February 28, 2017, signed by Traci Graham. Fidelity Investments check 1056, Graham Family Partnership I, LP. To Cunningham Development, $14,539.21, April 10, 2017, signed by Traci Graham, with hand written change order note. Fidelity Investments check 1057, Graham Family Partnership I, LP. To Cunningham Development, signed by Traci Graham. Fidelity Investments check 1060, Graham Family Partnership I, LP. To Cunningham Development, $12,792.36, June 1, 2017, signed by Traci Graham. Fidelity Investments check 1062, Graham Family Partnership I, LP. To Cunningham Development, $4,574.00, June 27, 2017, signed by Traci Graham. Email by Todd Graham June 20, 2017 to Amy Scobee at First Federal. (“paid directly Business records of Bank of America, March Business records of JP Morgan Chase, April Seth Kretzer, Receiver, v. Traci Rose Graham No. Receiver’s Supporting Exhibits for his Response to Traci Graham’s Motion for Summary Judgment Page Secretary of State Records for SuperOx Holdings, LLC Secretary of State Records for First Third Capital Management, LLC Secretary of State Records for First Third Capital Partners II, LLC Secretary of State Records for FIT Management, LLC Secretary of State Records for Family Partnership I, LP Secretary of State Records for MHT Partners Secretary of State Records for MHT Partners Management Company, LLC. Texas Secretary of State list of entities created by Todd Graham and Traci Graham. Russell Abshire, Post Oak Bank affidavit, Russell Abshire, Post Oak Bank declaration, Promissory Note in the original principal sum of $758,906.09 (the “SuperOx Note”). (See Russell Abshire declaration.) August 14, 2013 Commercial Guaranty agreement to pay Post Oak Bank the indebtedness of SuperOx (the “Graham Guaranty”). (See Russell Abshire declaration.) U.S. Federal Income Tax Returns Form 1040s submitted to Post Oak Bank for the years 2010 to 2012 (See Russell Abshire declaration.) Graham balance sheet dated December 10, 2013 and a balance sheet dated June 30, submitted to Post Oak Bank. (See Russell Abshire declaration.) August 26, 2014 Post Oak Bank Promissory Note to the Graham Family Partnership I, LP $1,317,500. (See Russell Abshire declaration.) Declaration of Charles H. Carmouche, Post. Seth Kretzer, Receiver, v. Traci Rose Graham No. Receiver’s Supporting Exhibits for his Response to Traci Graham’s Motion for Summary Judgment Page Oak Bank, now Allegiance Bank, July Post Oak Bank Release of Lien Declaration of Mr. Robert Kruckemeyer, attorney for Post Oak Bank, now Allegiance Letter of February 12, 2016, Manfred Sternberg, Graham’s attorney February 2016 Quitclaim Deed whereby Graham and Traci conveyed ownership of the Burkhardt Residence back to Family Partnership February 2016 Request to Remove Homestead Exemption for filing with the Harris County Appraisal District removing the homestead exemption from the Burkhardt Residence. Affidavit of Seth Kretzer, Receiver. File separately, incorporated by reference into MSJ response and this list of exhibits.) Respectfully submitted day of th Kiger ETH RETZER RETZER OLBERDING The Lyric Center 440 Louisiana, Ste. 1440 Houston, TX 77002 (713) 775 3050 (office) Email: seth@kretzerfirm.com ECEIVER Seth Kretzer, Receiver, v. Traci Rose Graham No. Receiver’s Supporting Exhibits for his Response to Traci Graham’s Motion for Summary Judgment Page Samos Wi Velberding By: JAMES W. VOLBERDING RETZER OLBERDING Plaza Tower 110 North College Avenue Suite 1850 Tyler, Texas 75702 (903) 597 6622 (Office) (866) 398 6883 (Fax) email: jamesvolberding@gmail.com TTORNEY FOR ECEIVER ERTIFICATE OF _ERVICE I hereby certify that a true and correct copy of this document has been delivered this ay of by electronic filing) to: Shawn R. McKee Casey Jon Lambright Lambright Mckee 940 Corbindale Rd. Houston, Texas 77024 (713) 840 (713) 840 fax cjl@lambrightlaw.com srm@lambrightlaw.com My. Todd D. Graham by the following means: By USS. Postal Service Certified Mail, R.R.R. By First Class U.S. Mail to Mr. Graham By Special Courier By Hand Delivery at hearing. Seth Kretzer, Receiver, v. Traci Rose Graham No. Receiver’s Supporting Exhibits for his Response to Traci Graham’s Motion for Summary Judgment Page By Fax before By Fax after email to By email with PDF — __ filing service. ¢/ th Tirtger SETH KRETZER Seth Kretzer, Receiver, v. Traci Rose Graham No. Receiver’s Supporting Exhibits for his Response to Traci Graham’s Motion for Summary Judgment Page