MTN:SUMMARY JUDGMENT

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                          Filed
11 July 29 P3:09
Amalia Rodriguez-Mendoza

District Clerk
Travis District
CAUSE NO, D-1-GN-11-000796 D-1-GN-11-000796
BEE CAVE (TX)—HC APARTMENTS IN THE DISTRICT COURT OF

SYNDICATED HOLDINGS, LLC

v.

HILL COUNTRY TEXAS GALLERIA
LLC, DILLARD TEXAS, LLC, ROBERT B.
BALDWIN, III,

WELLS FARGO BANK N.A., and

RS BACK WOODS HOLDINGS AUSTIN,
LLC

TRAVIS COUNTY, TEXAS

LPL LP LP LP LP LP LP LP LP LP

353? JUDICIAL DISTRICT
DEFENDANT HILL COUNTRY TEXAS GALLERIA LLC’S

MOTION FOR PARTIAL SUMMARY JUDGMENT
REGARDING THE COREA’S CAM ELECTION PROVISIONS

Defendant Hill Country Texas Galleria LLC (“Galleria”) files this Motion for Partial
Summary Judgment against Bee Cave (TX)—HC Apartments Syndicated Holdings, LLC (“Bee
Cave”). The Court should rule as a matter of law that: (1) under section 6.5 of the COREA,
Galleria (as the “Developer”) may use a CAM Election to impose a Common Area Maintenance
Cost obligation on Bee Cave that applies to all common area maintenance costs incurred by
Galle…