10-22-2012 - Motion - Leave CV - DC1104489 - 11164122 - MOTION - LEAVE - TOM KARTSOTIS vs. RICHARD BLOCH, et al

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On April 8, 2011 a case was filed by Kartsotis, Tom, represented by Conway, Ladawn Horn, Copling, Jason, Frazier, Charles T, and Reneker, D Ronald, against Bedrock Dirt, L.P.,, Bloch, Richard L, Nancy Bloch, Trustee, and Richard L Bloch Trustee, represented by Cecere, Joseph C, Goldfarb, Jeffrey, Hankinson, Deborah G., Reneker, D Ronald, and Thompson, William R, in the jurisdiction of Dallas County. Judge TILLERY, DALE presiding.

                        
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                          FILED

[200722 PH 2:02

CAUSE NO. DC-11-04489
TOM KARTSOTIS,
Plaintiff / Counter-Defendant,
ve

CLB CAPITAL PARTNERS, LP, CLB
CAPITAL PARTNERS, GP, LLC,
RICHARD BLOCH, INDIVIDUALLY
AND AS TRUSTEE OF THE
RICHARD AND NANCY BLOCH
FAMILY TRUST, and NANCY
BLOCH, AS TRUSTEE OF THE
RICHARD AND NANCY BLOCH
FAMILY TRUST,

DUP OD LP LP LAP LP LP SP LP AP? LP LP LP UP LP

Defendants / Counter-Plaintiffs. DALLAS COUNTY, TEXAS

DEFENDANTS/COUNTERCLAIMANTS’ REJOINDER AND MOTION FOR LEAVE
TO FILE SUPPLEMENTAL BRIEFING ON SUMMARY JUDGMENT ISSUES

Defendants/Counterclaimants Richard L. Bloch and Nancy Bloch (the “Blochs”) file this
Rejoinder and Motion for Leave to File Supplemental Briefing on Summary Judgment Issues. As
Plaintiff Tom Kartsotis (‘“Kartsotis”) apparently objects to the submission of supplemental
briefing, the Blochs respectfully request that the Court enter an order formally allowing the
briefing.

A. Rejoinder to Tom Kartsotis’ October 17, 2012 contentions.

The Court conducted a hea…