On November 01, 2019 a
Letter,Correspondence
was filed
involving a dispute between
Janet Northrup,,
and
2818 Ventures, Llc,
84 Grove Dev, Llc,
Abode Multi-Family, Lp,
Abode New Development, Llc,
American Capital Advisors, Llc,
Btx Multifamily, Llc,
Forrest Pines Bryan 84, Llc,
Fp Bryan 240 Gp, Llc,
Fp Bryan 240, Ltd,
Kramer, William,
Lapp, Richard,
Myan Management Group, Llc,
Pillar Income Asset Management, Inc,
Reynolds, James Mikel,
Southern Properties Capital, Lotd,
Southwestern Apartment Developers, Llc,
Transcontinental Realty Investors, Inc,
Woodward, Bruce,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
Preview
FILED
1/10/2022 7:57 AM
v
FELICIA PITRE
DISTRICT CLERK
v DALLAS CO., TEXAS
Lafonda Sims DEPUTY
SELANDER
QUILLING
- -
VA
LOWNDS-
WINSLETT
-MOSER
A PROFESSIONAL CORPORATION
ATTORNEYS AND COUNSELORS
2001 BRYAN STREET, SUITE 1800
DALLAS, TEXAS 75201
GREGORY M. SUDBURY
Direct: (214) 880-1878 Phone: (214)871-2100
Email: gsudbury@qslwm.com Fax: (214) 871-21 1 1
January 10, 2022
Via EF ile. Texas. gov
Honorable Judge Ashley Wysocki
George L. Allen, Sr. Courts Building
600 Commerce Street
5th Floor New Tower
Dallas, TX 75202
Re: Janet Northrup, Chapter 7 Trustee for the Estate of FM Forrest, Inc. v. Pillar
Income Asset Management, Inc., et al.; Cause No. DC-19-17636 in the 44th Judicial
District Court, Dallas County, Texas (the “Lawsuit”)
Honorable Judge Wysocki:
This Lawsuit is currently on the docket for jury trial on February 7, 2022. A hearing in
this Lawsuit was conducted on December 16, 2021 regarding Defendants’ Joint Motion to Compel
Discovery. During the hearing, there was discussion related to the trial setting. You advised this
Lawsuit is set number two for a jury trial on its current docket setting. Plaintiff’s counsel confirmed
they requested this matter stay on the jury docket and the parties agreed this was likely a one-week
jury trial.
You identified the key issue was whether the Court would be able to have a jury available
and stated you were “not exactly sure.” Given the recent surge of the COVID-19 Omicron variant
in Dallas County since our prior hearing, I assume the feasibility of jury trial in early February is
even more uncertain.
Given these circumstances, and the challenges of trial preparation for this complex multi-
party Lawsuit, my clients respectfillly request a brief (fifteen to thirty minute) telephonic status
conference as soon as it is practical for the Court to discuss the Court’s current jury trial
procedures, the current jury trial setting and its feasibility, and whether it would benefit the Court
and the parties to consider alternative trial settings. I conferred with counsel for Plaintiff and co-
Defendants who indicated they are willing to participate in a status conference call.
If the Court could please let me know whether a brief telephonic status conference is
possible and the Court’s availability, I will make the arrangements for the call and/or follow any
instructions provided by the Court.
We appreciate Your Honor’s attention to this matter.
Sincerely
/S/ Gregory M Sudbury
Gregory M. Sudbury
Counsel for Defendants Pillar Income Asset
Management, Inc. and Abode New Development,
LLC
cc: All counsel of record (Via eFile.Texas. gov)
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Ana Canson on behalf of Gregory Sudbury
Bar No. 24033367
acanson@qslwm.com
Envelope ID: 60642622
Status as of 1/10/2022 9:31 AM CST
Associated Case Party: FP BRYAN 240, LTD
Name BarNumber Email TimestampSubmitted Status
E. F. ManoDeAyala deayala@buckkeenan.com 1/10/2022 7:57:37 AM SENT
Helen McLaughlin hmclaughlin@buckkeenan.com 1/10/2022 7:57:37 AM SENT
Robert LawtonPaddock rpaddock@buckkeenan.com 1/10/2022 7:57:37 AM SENT
Associated Case Party: AMERICAN CAPITAL ADVISORS, LLC
Name BarNumber Email TimestampSubmitted Status
Robert Blackwell bblackwell@bbhsllp.com 1/10/2022 7:57:37 AM SENT
Lindsey Reinhardt lreinhardt@bbhsllp.com 1/10/2022 7:57:37 AM SENT
Sharon Bruner sbruner@bbhsllp.com 1/10/2022 7:57:37 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Allen Linn Williamson 24003305 awilliamson@bpwlaw.com 1/10/2022 7:57:37 AM SENT
Lynnette Shaw lshaw@bpwlaw.com 1/10/2022 7:57:37 AM SENT
Matthew Meyer mmeyer@bpwlaw.com 1/10/2022 7:57:37 AM SENT
Hudson M.Jobe hjobe@qslwm.com 1/10/2022 7:57:37 AM SENT
DERRICK S. BOYD dboyd@bpwlaw.com 1/10/2022 7:57:37 AM SENT
Scott Lindsey slindsey@bpwlaw.com 1/10/2022 7:57:37 AM SENT
Ian B.Salzer isalzer@qslwm.com 1/10/2022 7:57:37 AM SENT
Dalene Gantt dgantt@bpwlaw.com 1/10/2022 7:57:37 AM SENT
Associated Case Party: FORREST PINES BRYAN 84, LLC
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Ana Canson on behalf of Gregory Sudbury
Bar No. 24033367
acanson@qslwm.com
Envelope ID: 60642622
Status as of 1/10/2022 9:31 AM CST
Associated Case Party: FORREST PINES BRYAN 84, LLC
Name BarNumber Email TimestampSubmitted Status
Caleb Rawls caleb@calebrawlslaw.com 1/10/2022 7:57:37 AM SENT
Associated Case Party: TRANSCONTINENTAL REALTY INVESTORS, INC
Name BarNumber Email TimestampSubmitted Status
Caleb Rawls caleb@calebrawlslaw.com 1/10/2022 7:57:37 AM SENT
Michael J. Merrick mmerrick@condontobin.com 1/10/2022 7:57:37 AM SENT
Associated Case Party: SOUTHERN PROPERTIES CAPITAL, LOTD
Name BarNumber Email TimestampSubmitted Status
Caleb Rawls calebrawls@gmail.com 1/10/2022 7:57:37 AM SENT
Associated Case Party: ABODE MULTl-FAMILY, LP
Name BarNumber Email TimestampSubmitted Status
Caleb Rawls calebrawls@gmail.com 1/10/2022 7:57:37 AM SENT
Document Filed Date
January 10, 2022
Case Filing Date
November 01, 2019
Category
CNTR CNSMR COM DEBT
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED 1/10/2022 7:57 AM v FELICIA PITRE DISTRICT CLERK v DALLAS CO., TEXAS Lafonda Sims DEPUTY SELANDER QUILLING - - VA LOWNDS- WINSLETT -MOSER A PROFESSIONAL CORPORATION ATTORNEYS AND COUNSELORS 2001 BRYAN STREET, SUITE 1800 DALLAS, TEXAS 75201 GREGORY M. SUDBURY Direct: (214) 880-1878 Phone: (214)871-2100 Email: gsudbury@qslwm.com Fax: (214) 871-21 1 1 January 10, 2022 Via EF ile. Texas. gov Honorable Judge Ashley Wysocki George L. Allen, Sr. Courts Building 600 Commerce Street 5th Floor New Tower Dallas, TX 75202 Re: Janet Northrup, Chapter 7 Trustee for the Estate of FM Forrest, Inc. v. Pillar Income Asset Management, Inc., et al.; Cause No. DC-19-17636 in the 44th Judicial District Court, Dallas County, Texas (the “Lawsuit”) Honorable Judge Wysocki: This Lawsuit is currently on the docket for jury trial on February 7, 2022. A hearing in this Lawsuit was conducted on December 16, 2021 regarding Defendants’ Joint Motion to Compel Discovery. During the hearing, there was discussion related to the trial setting. You advised this Lawsuit is set number two for a jury trial on its current docket setting. Plaintiff’s counsel confirmed they requested this matter stay on the jury docket and the parties agreed this was likely a one-week jury trial. You identified the key issue was whether the Court would be able to have a jury available and stated you were “not exactly sure.” Given the recent surge of the COVID-19 Omicron variant in Dallas County since our prior hearing, I assume the feasibility of jury trial in early February is even more uncertain. Given these circumstances, and the challenges of trial preparation for this complex multi- party Lawsuit, my clients respectfillly request a brief (fifteen to thirty minute) telephonic status conference as soon as it is practical for the Court to discuss the Court’s current jury trial procedures, the current jury trial setting and its feasibility, and whether it would benefit the Court and the parties to consider alternative trial settings. I conferred with counsel for Plaintiff and co- Defendants who indicated they are willing to participate in a status conference call. If the Court could please let me know whether a brief telephonic status conference is possible and the Court’s availability, I will make the arrangements for the call and/or follow any instructions provided by the Court. We appreciate Your Honor’s attention to this matter. Sincerely /S/ Gregory M Sudbury Gregory M. Sudbury Counsel for Defendants Pillar Income Asset Management, Inc. and Abode New Development, LLC cc: All counsel of record (Via eFile.Texas. gov) Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Ana Canson on behalf of Gregory Sudbury Bar No. 24033367 acanson@qslwm.com Envelope ID: 60642622 Status as of 1/10/2022 9:31 AM CST Associated Case Party: FP BRYAN 240, LTD Name BarNumber Email TimestampSubmitted Status E. F. ManoDeAyala deayala@buckkeenan.com 1/10/2022 7:57:37 AM SENT Helen McLaughlin hmclaughlin@buckkeenan.com 1/10/2022 7:57:37 AM SENT Robert LawtonPaddock rpaddock@buckkeenan.com 1/10/2022 7:57:37 AM SENT Associated Case Party: AMERICAN CAPITAL ADVISORS, LLC Name BarNumber Email TimestampSubmitted Status Robert Blackwell bblackwell@bbhsllp.com 1/10/2022 7:57:37 AM SENT Lindsey Reinhardt lreinhardt@bbhsllp.com 1/10/2022 7:57:37 AM SENT Sharon Bruner sbruner@bbhsllp.com 1/10/2022 7:57:37 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Allen Linn Williamson 24003305 awilliamson@bpwlaw.com 1/10/2022 7:57:37 AM SENT Lynnette Shaw lshaw@bpwlaw.com 1/10/2022 7:57:37 AM SENT Matthew Meyer mmeyer@bpwlaw.com 1/10/2022 7:57:37 AM SENT Hudson M.Jobe hjobe@qslwm.com 1/10/2022 7:57:37 AM SENT DERRICK S. BOYD dboyd@bpwlaw.com 1/10/2022 7:57:37 AM SENT Scott Lindsey slindsey@bpwlaw.com 1/10/2022 7:57:37 AM SENT Ian B.Salzer isalzer@qslwm.com 1/10/2022 7:57:37 AM SENT Dalene Gantt dgantt@bpwlaw.com 1/10/2022 7:57:37 AM SENT Associated Case Party: FORREST PINES BRYAN 84, LLC Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Ana Canson on behalf of Gregory Sudbury Bar No. 24033367 acanson@qslwm.com Envelope ID: 60642622 Status as of 1/10/2022 9:31 AM CST Associated Case Party: FORREST PINES BRYAN 84, LLC Name BarNumber Email TimestampSubmitted Status Caleb Rawls caleb@calebrawlslaw.com 1/10/2022 7:57:37 AM SENT Associated Case Party: TRANSCONTINENTAL REALTY INVESTORS, INC Name BarNumber Email TimestampSubmitted Status Caleb Rawls caleb@calebrawlslaw.com 1/10/2022 7:57:37 AM SENT Michael J. Merrick mmerrick@condontobin.com 1/10/2022 7:57:37 AM SENT Associated Case Party: SOUTHERN PROPERTIES CAPITAL, LOTD Name BarNumber Email TimestampSubmitted Status Caleb Rawls calebrawls@gmail.com 1/10/2022 7:57:37 AM SENT Associated Case Party: ABODE MULTl-FAMILY, LP Name BarNumber Email TimestampSubmitted Status Caleb Rawls calebrawls@gmail.com 1/10/2022 7:57:37 AM SENT