On July 08, 2016 a
Motion-Secondary
was filed
involving a dispute between
Peregrine Oil & Gas Lp,
and
Hrb Oil & Gas Ltd,
Vhpm Llc,
for HOMEOWNERS ASSOCIATION
in the District Court of Harris County.
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CAUSE NO. 2016-45652
PEREGRINE OIL & GAS, LP § IN THE DISTRICT COURT OF
Plaintiff, §
§ HARRIS COUNTY, TEXAS
HRB OIL & GAS, Ltd. and
VHPM, LLC
Defendants. § 190th JUDICIAL DISTRICT
PLAINTIFF’S REPLY
TO
DEFENDANTS’ RESPONSE TO MOTION TO MODIFY JUDGMENT
Subject to the July 21, 2021 MOTION FOR NEW TRIAL and in the alternative
Plaintiff, PEREGRINE OIL & GAS LP (hereinafter “”), files this REPLY TO
DEFENDANTS’ RESPONSE TO Peregrine’s MOTION TO MODIFY JUDGMENT
pursuant to Rule 329b, Tex.R.Civ.P., in the above captioned matter, and states:
Defendants, HRB OIL & GAS, Ltd. and VHPM, LLC, fail to address the
central question raised in Peregrine’s Motion to Modify. Defendants have no pleadings to
support Defendants’ claim for the $50,069.43. Defendants skirt this issue and can point to
nothing in the record where Peregrine tried this issue by consent.
Defendants have no evidence except counsel’s ipse dixit that the attorneys’
fee award should be $12,000 for the recovery of the unpaid Joint Interest Billings. The
claim for unpaid Joint Interest Billings was a part of this litigation for three and one half
years. The proposed amount of $29,040 is supported by the hourly invoices submitted as
Plaintiff’s Exhibit 23 consistent with Rohrmoos Venture v. UTSW DVA Healthcare, LLP,
578 S.W.3d 469 (Tex. 2019).
WHEREFORE, Premises considered, Peregrine requests this Court to MODIFY the
June 25, 2021 judgment Defendants to pay Peregrine $107,236.02 and to order an
increase in the award of attorneys’ fees from $12,000.00 to $29,040.00 and for Defendant
to submit a modified and corrected Final Judgment with pre judgment interest calculated
upon the unpaid balance of $107,236.02 within seven (7) days of this Order and for such
other and further relief to which Peregrine may show itself justly entitled.
Respectfully submitted,
ONES ILL ORTER RAWFORD
RAWFORD LLP
/s/ Michael D. Jones
chael D. Jones
mjones@jonesgill.com
Texas Bar No. 10929350
Joseph D. Porter
jporter@jonesgill.com
State Bar No.
6363 Woodway, Suite 1100
Houston, Texas 77057
Telephone: (713)652 4068
Facsimile: (713)651 0716
TTORNEYS FOR LAINTIFF
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on July 29, 2021 a true and correct copy of the
foregoing documentwas electronically served o n the following counsel of record:
Barry F. Cannaday
Dentons US LLP
2000 McKinney Ave. Suite 1900
Dallas, Texas 75201
0900(telephone)
0910 (facsimile)
barry.cannaday@dentons.com
/s/ Michael D. Jones
Michael D. Jones
Document Filed Date
July 29, 2021
Case Filing Date
July 08, 2016
Category
HOMEOWNERS ASSOCIATION
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CAUSE NO. 2016-45652 PEREGRINE OIL & GAS, LP § IN THE DISTRICT COURT OF Plaintiff, § § HARRIS COUNTY, TEXAS HRB OIL & GAS, Ltd. and VHPM, LLC Defendants. § 190th JUDICIAL DISTRICT PLAINTIFF’S REPLY TO DEFENDANTS’ RESPONSE TO MOTION TO MODIFY JUDGMENT Subject to the July 21, 2021 MOTION FOR NEW TRIAL and in the alternative Plaintiff, PEREGRINE OIL & GAS LP (hereinafter “”), files this REPLY TO DEFENDANTS’ RESPONSE TO Peregrine’s MOTION TO MODIFY JUDGMENT pursuant to Rule 329b, Tex.R.Civ.P., in the above captioned matter, and states: Defendants, HRB OIL & GAS, Ltd. and VHPM, LLC, fail to address the central question raised in Peregrine’s Motion to Modify. Defendants have no pleadings to support Defendants’ claim for the $50,069.43. Defendants skirt this issue and can point to nothing in the record where Peregrine tried this issue by consent. Defendants have no evidence except counsel’s ipse dixit that the attorneys’ fee award should be $12,000 for the recovery of the unpaid Joint Interest Billings. The claim for unpaid Joint Interest Billings was a part of this litigation for three and one half years. The proposed amount of $29,040 is supported by the hourly invoices submitted as Plaintiff’s Exhibit 23 consistent with Rohrmoos Venture v. UTSW DVA Healthcare, LLP, 578 S.W.3d 469 (Tex. 2019). WHEREFORE, Premises considered, Peregrine requests this Court to MODIFY the June 25, 2021 judgment Defendants to pay Peregrine $107,236.02 and to order an increase in the award of attorneys’ fees from $12,000.00 to $29,040.00 and for Defendant to submit a modified and corrected Final Judgment with pre judgment interest calculated upon the unpaid balance of $107,236.02 within seven (7) days of this Order and for such other and further relief to which Peregrine may show itself justly entitled. Respectfully submitted, ONES ILL ORTER RAWFORD RAWFORD LLP /s/ Michael D. Jones chael D. Jones mjones@jonesgill.com Texas Bar No. 10929350 Joseph D. Porter jporter@jonesgill.com State Bar No. 6363 Woodway, Suite 1100 Houston, Texas 77057 Telephone: (713)652 4068 Facsimile: (713)651 0716 TTORNEYS FOR LAINTIFF CERTIFICATE OF SERVICE The undersigned hereby certifies that on July 29, 2021 a true and correct copy of the foregoing documentwas electronically served o n the following counsel of record: Barry F. Cannaday Dentons US LLP 2000 McKinney Ave. Suite 1900 Dallas, Texas 75201 0900(telephone) 0910 (facsimile) barry.cannaday@dentons.com /s/ Michael D. Jones Michael D. Jones