Evidence Record
Plaintiff’s Motion to Compel and Response to Cyberlux Corporation and Mark D. Schmidt’s Motion for Protective Order and Motion to Quash Atlantic Wave Holding’s Subpoena Duces Tecum and Deposition on Written Questions
1. On July 30, 2024, Plaintiffs filed its Petition to Enforce Foreign Judgment, of its approximately $1.5 million judgment rendered in Virginia against Defendants ("Texas Judment").
DISTIL analysis
DISTIL Run
Profile
Standard
Version
1
Doc Type
Motion to Compel and Response
Total Nodes
38
Node Legend
Entity (ENT)
Event (EVT)
Claim (CLM)
Anchor (ANC)
Omission (OMI)
Tension (TEN)
Tell (TEL)
Inference (INF)
Hypothesis (HYP)
Stage 1
Index
Orientation · No nodes
Document Classification
Motion to Compel and Response Plaintiff's counsel (Shawn M. Grady) Texas post-judgment enforcement proceedings 2024-07-30 to 2024-11-08
misrepresentation_allegeddiscovery_disputeforeign_judgment_enforcement
Analytical Frame
Discovery dispute regarding witness depositions and document production
Analytical Summary
Atlantic Wave Holdings and Secure Community filed a motion to compel depositions of two Cyberlux executives (Neil Whiteley and Phillip Tucker) in post-judgment enforcement proceedings for a $1.5 million Virginia judgment domesticated in Texas. Plaintiffs allege defendants' counsel misrepresented the witnesses' positions during meet-and-confer discussions on August 21, 2024, leading plaintiffs to agree to limited 30-minute depositions based on the false premise that witnesses had minimal knowledge of Cyberlux operations. Plaintiffs later discovered Whiteley is Senior Vice President and former owner of a business acquired by Cyberlux, contradicting counsel's representations. The court previously denied defendants' motion to vacate and imposed a 30-day execution stay while expressly permitting discovery to proceed.
Key Points
- Plaintiffs seek to enforce $1.5 million Virginia judgment against Cyberlux Corporation and Mark D. Schmidt in Texas
- Defendants' counsel allegedly misrepresented that deponents Neil Whiteley and Phillip Tucker had minimal knowledge of Cyberlux operations
- Whiteley is actually Senior Vice President and former owner of acquired business, contradicting representation
- Plaintiffs agreed to 30-minute deposition limit based on misrepresentation that witnesses were not executives
- Court denied motion to vacate judgment and imposed 30-day execution stay but allowed discovery to proceed
- Plaintiffs request full 6-hour depositions per Texas Rules and production of financial documents
Stage 2
Core — Entities, Events, Claims
23 nodes
ENT-001
Entity
Atlantic Wave Holdings, LLC
Plaintiff and judgment creditor in enforcement action seeking to collect approximately $1.5 million judgment rendered in Virginia
Page 1 — COME NOW Plaintiff Atlantic Wave Holdings, LLC and Secure Community, LLC, ("hereinafter collectively "Plaintiffs") files this Motion to Compel
ENT-002
Entity
Secure Community, LLC
Co-plaintiff and judgment creditor in enforcement action alongside Atlantic Wave Holdings
Page 1 — COME NOW Plaintiff Atlantic Wave Holdings, LLC and Secure Community, LLC, ("hereinafter collectively "Plaintiffs") files this Motion to Compel
ENT-003
Entity
Cyberlux Corporation
Defendant and judgment debtor in enforcement proceedings, subject of post-judgment discovery regarding financial condition and operations
Page 1 — CYBERLUX CORPORATION and MARK D. SCHMIDT, Individually, Defendant/Judgment-Debtors
ENT-004
Entity
Mark D. Schmidt
Individual defendant and judgment debtor named alongside Cyberlux Corporation
Page 1 — CYBERLUX CORPORATION and MARK D. SCHMIDT, Individually, Defendant/Judgment-Debtors
ENT-005
Entity
Neil Whiteley
Senior Vice President of Cyberlux Corporation and former owner of business acquired by Cyberlux, subject of deposition subpoena
Page 3 — Specifically, Plaintiffs have learned that Mr. Whitely holds the title of Senior Vice President and that he also formally owned the company prior to selling the business to Cyberlux.
ENT-006
Entity
Phillip Tucker
Executive employee of Cyberlux Corporation, subject of deposition subpoena
Page 2 — Defendant Cyberlux filed its Motion for Protection to prevent the depositions of Phillip Tucker and Neil Whitely, both employees of Defendant Cyberlux.
ENT-007
Entity
Shawn M. Grady
Attorney for plaintiffs, counsel of record representing Atlantic Wave Holdings and Secure Community
Page 5 — Shawn M. Grady SBN 24076411 shawn@gradycollectionlaw.com 2100 West Loop South, Ste. 805 Houston, Texas 77027 ATTORNEY FOR PLAINTIFFS
ENT-008
Entity
Alex Pennetti
Attorney for defendants Cyberlux Corporation and Mark D. Schmidt
Page 2 — On August 21, 2024, counsel for Plaintiffs, Mr. Shawn Grady, and counsel for Defendants, Mr. Alex Pennetti, held a phone call to conference regarding the requested depositions.
EVT-001
Event
Filing of Petition to Enforce Foreign Judgment
On July 30, 2024, plaintiffs filed petition to enforce approximately $1.5 million Virginia judgment against defendants in Texas
Page 1 — On July 30, 2024, Plaintiffs filed its Petition to Enforce Foreign Judgment, of its approximately $1.5 million judgment rendered in Virginia against Defendants ("Texas Judment").
EVT-002
Event
Service of Whiteley Deposition Subpoena
On August 14, 2024, plaintiffs served notice of oral deposition and subpoena duces tecum for Neil Whiteley, scheduled for August 27, 2024
Page 1 — On August 14, 2024, Plaintiffs served its Notice of Oral Deposition of Neil Whiteley and Subpoena Duces Tecum ("Whiteley Depo Subpoena") to take Mr. Whiteley's deposition, remotely, on August 27, 2024.
EVT-003
Event
Service of Tucker Deposition Subpoena
Plaintiffs served notice of oral deposition and subpoena duces tecum for Phillip Tucker, scheduled for August 27, 2024
Page 2 — In addition, Plaintiffs served its Notice of Oral Deposition of Phillip Tucker and Subpoena Duces Tecum ("Tucker Depo Subpoena"), to take Mr. Tucker's deposition, remotely, on August 27, 2024.
EVT-004
Event
Defendants' Motions to Quash Subpoenas
On August 20, 2024, Cyberlux filed motions to quash both the Whiteley and Tucker deposition subpoenas
Page 2 — On August 20, 2024, Defendant Cyberlux filed its Motion to Quash the Whiteley Depo Subpoena and its Motion to Quash the Tucker Depo Subpoena.
EVT-005
Event
Meet and Confer Phone Call
On August 21, 2024, opposing counsel Shawn Grady and Alex Pennetti held phone conference regarding requested depositions
Page 2 — On August 21, 2024, counsel for Plaintiffs, Mr. Shawn Grady, and counsel for Defendants, Mr. Alex Pennetti, held a phone call to conference regarding the requested depositions.
EVT-006
Event
Motion for Protection Filed
On August 23, 2024, Cyberlux filed motion for protection to prevent depositions of Tucker and Whiteley
Page 2 — On August 23, 2024, Defendant Cyberlux filed its Motion for Protection to prevent the depositions of Phillip Tucker and Neil Whitely, both employees of Defendant Cyberlux.
EVT-007
Event
Motion to Vacate and Stay Filed
On August 23, 2024, defendants filed motion to vacate and motion to stay the Texas judgment
Page 2 — On August 23, 2024, Defendants filed their Motion to Vacate and Motion to Stay.
EVT-008
Event
Court Ruling on Motion to Vacate
On October 28, 2024, court denied defendants' motion to vacate, issued 30-day stay on execution, but expressly permitted discovery to proceed
Page 2 — After oral hearing, on October 28, 2024, the Court denied Defendants' Motion to Vacate and issued a 30-day stay on execution of the Texas Judgment, but expressly ruled that Plaintiffs may proceed with discovery
EVT-009
Event
Filing of Motion to Compel
On November 8, 2024, plaintiffs filed motion to compel depositions and response to defendants' protective order motion
Page 1 — 11/8/2024 6:25 PM Marilyn Burgess - District Clerk Harris County Envelope No. 94119891 By: Sharelldahaetor Filed: 11/8/2024 6:25 PM
CLM-001
Claim
Misrepresentation of Witness Knowledge
Plaintiffs allege defendants' counsel Alex Pennetti misrepresented that deponents Neil Whiteley and Phillip Tucker had minimal knowledge of Cyberlux operations during August 21, 2024 conference
Page 2 — During the meet and confer call on August 21, 2024, Defendants' counsel, Mr. Pennetti represented that Deponents knew little about Defendant Cyberlux.
CLM-002
Claim
Agreement to Limited Deposition Time
Plaintiffs agreed to limit depositions to 30 minutes each based on representation that witnesses were not executives and had no knowledge of Cyberlux operations
Page 2 — Plaintiffs' counsel and Plaintiffs' representative on the phone call suggested that if Deponents were not executives of Defendant Cyberlux and had no knowledge of the operations of Cyberlux, the deposition could be concluded expeditiously, and agreed to limit the depositions to 30 minutes each.
CLM-003
Claim
Whiteley's Executive Position
Plaintiffs discovered that Neil Whiteley holds title of Senior Vice President and formerly owned company prior to selling business to Cyberlux
Page 3 — Specifically, Plaintiffs have learned that Mr. Whitely holds the title of Senior Vice President and that he also formally owned the company prior to selling the business to Cyberlux.
CLM-004
Claim
Agreement Based on False Premise
Plaintiffs' agreement to limit time and scope was predicated on misleading suggestion that witnesses were not executives and knew nothing about Cyberlux
Page 3 — Plaintiffs agreement to limit its time (30 minutes) and Subpoena Duces Tecum was predicted on the misleading suggestion that the witnesses knew nothing about Cyberlux and were not executives.
CLM-005
Claim
Defendants Did Not Honor Agreement
Defendants did not honor the informal agreement regarding deposition limitations but now seek court enforcement of that agreement
Page 3 — Regardless, Defendants did not honor the agreement anyway which they now ask the Court to enforce, and filed their Motion for Protection.
CLM-006
Claim
Entitlement to Full Post-Judgment Discovery
Plaintiffs assert entitlement to depose Cyberlux executives for up to 6 hours each and obtain standard post-judgment financial discovery under Texas Rule 621a
Page 4 — To enforce the Texas Judgment, Plaintiffs are entitled to depose witnesses of Defendant Cyberlux with knowledge of the financial condition of the company and its operations.
Stage 3
In Situ — Quotations, Tells, Tensions, Questions
10 nodes
QUO-001
Quotation
Burden on Discovery Opponent
Legal standard that party resisting discovery bears burden of proving request lies outside rule guidelines
Page 4 — In the trial court, the party resisting discovery bears the burden of proving the request lies outside the guidelines described by the rules and the supreme court.
QUO-002
Quotation
Post-Judgment Discovery Relevance Standard
Legal standard that post-judgment discovery relevance includes anything reasonably calculated to lead to material evidence aiding judgment enforcement
Page 3 — Relevance in the context of post-judgment discovery must be viewed generally in the same manner as in ordinary pretrial discovery, which includes anything reasonably calculated to lead to the discovery of material evidence. Material evidence includes any information that would aid in enforcement of the judgment.
TLL-001
Tell
Counsel Represented Minimal Witness Knowledge
Defense counsel's representation during conference that deponents knew little about Cyberlux operations
Page 2 — During the meet and confer call on August 21, 2024, Defendants' counsel, Mr. Pennetti represented that Deponents knew little about Defendant Cyberlux.
TLL-002
Tell
Good Faith Deposition Notice
Plaintiffs' characterization that initial deposition notices and agreement show good faith and intent not to waste time
Page 4 — If anything the agreement shows that Plaintiffs noticed these depositions in good faith and do not seek to waste anyone's time.
TEN-001
Tension
Representation vs. Actual Executive Status
Conflict between defense counsel's representation that witnesses had minimal knowledge and subsequent discovery that Whiteley is Senior VP and former owner
Page 3 — However, since this informal agreement was made, Plaintiffs' have discovered that Defendant's counsel, Mr. Pannetti misrepresented the positions Deponents held at Cyberlux. Specifically, Plaintiffs have learned that Mr. Whitely holds the title of Senior Vice President and that he also formally owned the company prior to selling the business to Cyberlux.
TEN-002
Tension
Agreement Enforcement Asymmetry
Defendants allegedly did not honor the informal agreement but now seek court enforcement of that same agreement to limit depositions
Page 3 — Regardless, Defendants did not honor the agreement anyway which they now ask the Court to enforce, and filed their Motion for Protection.
TEN-003
Tension
Discovery Permitted Despite Stay
Court imposed execution stay but expressly allowed discovery to proceed, creating operational framework for continued proceedings
Page 2 — After oral hearing, on October 28, 2024, the Court denied Defendants' Motion to Vacate and issued a 30-day stay on execution of the Texas Judgment, but expressly ruled that Plaintiffs may proceed with discovery
QST-001
Question
Nature of Business Acquired by Cyberlux
What business did Neil Whiteley formerly own before selling to Cyberlux, and what is its relevance to financial condition inquiry?
Page 3 — Specifically, Plaintiffs have learned that Mr. Whitely holds the title of Senior Vice President and that he also formally owned the company prior to selling the business to Cyberlux.
QST-002
Question
Basis for Voluminous Objections
What specific objections did defendants raise to standard post-judgment financial discovery requests, and on what grounds?
Page 4 — Defendants have issued voluminous and baseless objections to these discovery requests.
QST-003
Question
Tucker's Executive Position Details
What is Phillip Tucker's specific executive title and role at Cyberlux, contrasted with representations made about his knowledge?
Page 4 — Defendant Cyberlux admits that Neil Whiteley and Phillip Tucker are executives of Cyberlux, which would indicate that they have relevant knowledge.
Stage 4
Interpretive — Inferences, Omissions, Patterns
5 nodes
INF-001
Inference
Strategic Minimization of Witness Importance
Defense counsel's representation that witnesses had minimal knowledge appears to be strategic effort to limit deposition scope and duration
Page 2, 3 — Plaintiffs' counsel and Plaintiffs' representative on the phone call suggested that if Deponents were not executives of Defendant Cyberlux and had no knowledge of the operations of Cyberlux, the deposition could be concluded expeditiously, and agreed to limit the depositions to 30 minutes each.
INF-002
Inference
Whiteley's Unique Knowledge Position
Whiteley's dual status as Senior VP and former owner of acquired business suggests comprehensive knowledge of both historical operations and current Cyberlux financial condition
Page 3 — Specifically, Plaintiffs have learned that Mr. Whitely holds the title of Senior Vice President and that he also formally owned the company prior to selling the business to Cyberlux.
INF-003
Inference
Conditional Cooperation Strategy
Plaintiffs' agreement to limited depositions demonstrates willingness to cooperate conditionally, but only on basis of accurate factual representations
Page 4, 5 — If anything the agreement shows that Plaintiffs noticed these depositions in good faith and do not seek to waste anyone's time. Indeed, if the deponent party witnesses reveal that they possess little knowledge then the depositions will be brief, but in light of their executive positions, Plaintiffs should not be hamstrung limited to an agreement which is based on the misunderstanding or misrepresentation
OMI-001
Omission
Missing Details of Original Virginia Judgment
Document provides minimal detail about underlying Virginia judgment basis, amount precision, or nature of original claims
Page 1 — On July 30, 2024, Plaintiffs filed its Petition to Enforce Foreign Judgment, of its approximately $1.5 million judgment rendered in Virginia against Defendants
OMI-002
Omission
Substance of Amended Motion for Protection
Document mentions defendants filed amended motion for protection seeking limitations based on alleged agreement, but does not detail their specific arguments or legal basis
Page 2 — On or about the same date, Defendants filed their Amended Motion for Protection, seeking to impose limitations on the scope and length of the oral depositions based on an alleged agreement between counsel on August 21, 2024.
Extracted text
7 pages · 10242 charactersFiling Header
CAUSE NO. 2024-48085
ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC,
Plaintiff/Judgment-Creditor
V.
CYBERLUX CORPORATION and MARK D. SCHMIDT, Individually, §
§ IN THE DISTRICT COURT OF
§ §
§
§ §
§
§ § HARRIS COUNTY, TEXAS
Defendant/Judgment-Debtors § 129TH JUDICIAL COURT
PLAINTIFF'S MOTION TO COMPEL AND RESPONSE TO CYBERLUX CORPORATION AND MARK D. SCHMIDT'S MOTION FOR PROTECTIVE ORDER AND MOTION TO QUASH ATLANTIC WAVE HOLDING'S SUBPOENA DUCES TECUM AND DEPOSITION ON WRITTEN QUESTIONS
TO THE HONORABLE JUDGE OF SAID COURT:
Unfallical Copy Office Martin Bulunan strict Cler
COME NOW Plaintiff Atlantic Wave Holdings, LLC and Secure Community, LLC, ("hereinafter collectively "Plaintiffs") files this Motion to Compel and Response to Defendants Cyberlux Corporation and Mark D. Schmidt's Motion for Protective Order and Motion to Quash Atlantic Wave Holdings, LLC and Secure Community, LLC's Subpoena Duces Tecum and Deposition on Written Questions, and in support thereof, Plaintiffs would respectfully show the Court the following:
Background
1.
On July 30, 2024, Plaintiffs filed its Petition to Enforce Foreign Judgment, of its approximately $1.5 million judgment rendered in Virginia against Defendants ("Texas Judment").
2.
On August 14, 2024, Plaintiffs served its Notice of Oral Deposition of Neil Whiteley and Subpoena Duces Tecum ("Whiteley Depo Subpoena") to take Mr. Whiteley's deposition, remotely, on August 27, 2024.1
1
See Whiteley Depo Subpoena, attached hereto as Exhibit A.
3.
In addition, Plaintiffs served its Notice of Oral Deposition of Phillip Tucker and Subpoena Duces Tecum ("Tucker Depo Subpoena"), to take Mr. Tucker's deposition, remotely, on August 27, 2024.2
4.
On August 20, 2024, Defendant Cyberlux filed its Motion to Quash the Whiteley Depo Subpoena and its Motion to Quash the Tucker Depo Subpoena.
5.
On August 21, 2024, counsel for Plaintiffs, Mr. Shawn Grady, and counsel for Defendants, Mr. Alex Pennetti, held a phone call to conference;regarding the requested depositions.
6.
On August 23, 2024, Defendant Cyberlux filed its Motion for Protection to prevent the depositions of Phillip Tucker and Neil Whitely, both employees of Defendant Cyberlux.
7.
On August 23, 2024, Defendants filed their Motion to Vacate and Motion to Stay.
8.
After oral hearing, on October 28, 2024, the Court denied Defendants' Motion to Vacate and issued a 30-day stay on execution of the Texas Judgment, but expressly ruled that Plaintiffs may proceed with discovery
9.
On or about the same date, Defendants filed their Amended Motion for Protection, seeking to impose limitations on the scope and length of the oral depositions based on an alleged agreement between counselon August 2HARRIS1, 2024.
10.
During the meet and confer call on August 21, 2024, Defendants' counsel, Mr. Pennetti represented that Deponents knew little about Defendant Cyberlux. Plaintiffs' counsel and Plaintiffs' representative on the phone call suggested that if Deponents were not executives of Defendant Cyberlux and had no knowledge of the operations of Cyberlux, the deposition could be concluded expeditiously, and agreed to limit the depositions to 30 minutes each. As a matter of
2
See Tucker Depo Subpoena, attached hereto as Exhibit B.
efficiency, and for the same reasons, Plaintiffs further agreed to limit its Subpoena Duces Tecum on the Whiteley Depo Subpoena and Tucker Depo Subpoena.
11.
However, since this informal agreement was made, Plaintiffs' have discovered that Defendant's counsel, Mr. Pannetti misrepresented the positions Deponents held at Cyberlux. Specifically, Plaintiffs have learned that Mr. Whitely holds the title of Senior Vice President and that he also formally owned the company prior to selling the business to Cyberlux. Plaintiffs agreement to limit its time (30 minutes) and Subpoena Duces Tecum was predicted on the misleading suggestion that the witnesses knew nothing about Cyberlux and were not executives. Regardless, Defendants did not honor the agreement anyway@which they now ask the Court to enforce, and filed their Motion for Protection.
12.
As such, Plaintiffs are now forced to file this Motion to Compel so that they may conduct post-judgment discovery of Defendants via the oral depositions of two executives of Cyberlux, Neil Whiteley and Phillip Tucker, as permitted under the Texas Rules of Civil Procedure.
Arguments and Authorities
13.
Pursuant to Rule 621a of the Texas Rule of Civil Procedure, Plaintiff propounded the Whiteley Depo Subpoena and Tucker Depo Subpoena to Defendant Cyberlux, "for the purpose of obtaining information to aid in the enforcement" of its Texas judgment. See TEX. R. CIV. P. 621a. "Relevance in the context of post-judgment discovery must be viewed generally in the same manner as in ordinary pretrial discovery, which includes anything reasonably calculated to lead to the discovery of material evidence. Material evidence includes any information that would aid in enforcement of the judgment." See Blankinship v. Brown, 399 S.W.3d 303, 312 (Tex. App .- Dallas 2013, pet. Denied). Rule 193.1 of the Texas Rules of Civil Procedure requires a party to
make a "complete response" to a discovery request. TEX. R. CIV. P. 193.1. A trial court may compel a party to respond adequately to discovery. TEX. R. CIV. P. 215. In the trial court, the party resisting discovery bears the burden of proving the request lies outside the guidelines described by the rules and the supreme court. See Tex.R. Civ. P. 193.4(a). In re Rogers, 200 S. W 3d 318, 321- 22 (Tex. App .- Dallas 2006, no pet.) (financial information as to holding comprising the bulk of trusts assets was discoverable in beneficiary action).
14.
To enforce the Texas Judgment, Plaintiffs are entitled to depose witnesses of Defendant Cyberlux with knowledge of the financial condition of the company and its operations. Defendant Cyberlux admits that Neil Whiteley and Phillip Tucker are executives of Cyberlux, which would indicate that they have relevant knowledge. As such, Plaintiffs are entitled to depose these witnesses at a reasonable time and place, for up to 6 hours.3
15.
To accompany the deposition notices, Plaintiffs submitted identical Subpoena Duces Tecums with standard post-judgment discovery. Defendants have issued voluminous and baseless objections to these discovery requests. All of these requests go directly to the financial condition of the company and are relevant to aid in enforcement of the Texas Judgment. As such, Defendants' objections must be overruled.
16.
As to the prior agreement as to limitations on time and documents, Plaintiffs only agreed to this limitation on the premise that the witnesses had little knowledge of Defendant Cyberlux's financial condition or operations, which is clearly false. If anything the agreement shows that Plaintiffs noticed these depositions in good faith and do not seek to waste anyone's time. Indeed, if the deponent party witnesses reveal that they possess little knowledge then the depositions will be brief, but in light of their executive positions, Plaintiffs should not be
3
See Tex. R. Civ. P. 199.5(c).
hamstrung limited to an agreement which is based on the misunderstanding or misrepresentation that the deponents know very little about the Defendant Cyberlux. As such, Plaintiffs request that Defendants be compelled to present party witnesses Neil Whitely and Phillip Tucker, in the next fourteen (14) days, for remote deposition, and to overrule all objections to the documents requests in Plaintiffs' subpoena duces tecum, and produce documents within ten (10) days, and for such further relief to which Plaintiffs are entitled.
Respectfully submitted
LAW FIRM OF SHAWN M. GRADY, PLLC
By: /s/ Shawn M. Grady Shawn M. Grady SBN 24076411 shawn@gradycollectionlaw.com 2100 West Loop South, Ste. 805 Houston, Texas 77027 Phone (832) 692-4542 Fax (832) 565-1796
ATTORNEY FOR PLAINTIFFS
CERTIFICATE OF CONFERENCE
As described in this motion, Plaintiffs' counsel Mr. Grady and Defendants' counsel, Mr. Pennetti conferred by phone on or about August 21, 2024, and subsequently by email. Defendants are opposed to this motion.
/s/ Shawn M. Grady Shawn M. Grady
eden cial Copy Office of Marilyst Burgess District CierNe
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing instrument has been forwarded to all known counsel of record in accordance with the Texas Rules of Civil Procedure on this the 8th day of November 2024.
Unofficial Copy Office of Marilyn Burgess District Clerk
/s/ Shawn M. Grady Shawn M. Grady
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.
Shawn Grady on behalf of Shawn Grady Bar No. 24076411 shawn@gradycollectionlaw.com Envelope ID: 94119891
Filing Code Description: Motion (No Fee)
Filing Description: Plaintiffs' Motion to Compel and Response to Cyberlux Corporation and Mark D Schmidt Motion for Protective Order and Motion to Quash Plaintiff Subpoena Duces Tecum Status as of 11/11/2024 12:29 PM CST
Case Contacts
Name
BarNumber
Email Laburgess Distrise Clerk
TimestampSubmitted
Status
Shawn Grady
shawn@gradycollectionlaw.com
11/8/2024 6:25:40 PM
SENT
Sandra Meiners
smeiners@thompsoncoburn.com Pour
11/8/2024 6:25:40 PM
SENT
Laurie DeBardeleben
Idebardeleben@thompsoncoburn.com maps
11/8/2024 6:25:40 PM
SENT
Bernadette Martin
bernadette@gradycollectionlaw.com ed
11/8/2024 6:25:40 PM
SENT
Katharine Clark
kclark@thompsoncoburn.com Psa
11/8/2024 6:25:40 PM
SENT
Alex Pennetti
apennetti@thompsoncoburn.com BANCONEHerbei
11/8/2024 6:25:40 PM
SENT
Lena Brasher
Ibrasher@thompsoncoburn.com
11/8/2024 6:25:40 PM
SENT
Frankie Huff
:selected: fhuff@thompsoncoburn.com
11/8/2024 6:25:40 PM
SENT
Hannah Fischer
hfischer@thompsoncoburn.com
11/8/2024 6:25:40 PM
SENT
Unofficial Copy
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