Evidence Record

Defendants’ Response to Plaintiffs’ February 5, 2025 Request for Emergency Hearing

1. Despite demanding an emergency hearing in Texas, Atlantic Wave is currently telling the Virginia Court it is "not available" for an emergency hearing.

Type: document
Pages: 9
Lines: 294
SHA-256: 101d35f7b8de

DISTIL analysis

DISTIL Run

Profile

Standard

Version

Doc Type

Legal Response Motion

Total Nodes

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

Legal Response Motion Defense Counsel (Thompson Coburn LLP) Post-Judgment Collection Dispute, Receivership Opposition 2024-07-30 to 2025-02-07

multi_jurisdiction_conflictemergency_motion_oppositionsettlement_agreement_disputereceiver_appointment_contested

Analytical Frame

Procedural Defense Against Emergency Hearing Request

Analytical Summary

This defense response opposes Atlantic Wave's emergency hearing request in a Texas judgment enforcement case involving Cyberlux Corporation and Mark D. Schmidt. Defendants argue plaintiffs are engaging in procedural manipulation by demanding emergency relief in Texas while simultaneously blocking emergency hearings in Virginia, the contractually agreed venue for settlement disputes. The core dispute centers on whether a receiver should be appointed to enforce a Virginia judgment that defendants claim remains subject to ongoing Virginia litigation. Defendants contend plaintiffs' writ of execution became unnecessary once the court indicated it would appoint a receiver, and that defense communications with the Harris County Constable merely informed them of the pending receivership rather than obstructing collection. The response reveals a complex multi-jurisdictional enforcement battle where the underlying settlement agreement and judgment validity remain contested in Virginia courts.

Key Points

Defendants oppose Atlantic Wave's request for emergency hearing while plaintiffs simultaneously block emergency hearings in Virginia
Court indicated on January 16, 2025 it would appoint receiver but parties submitted competing orders
Underlying Virginia judgment stems from settlement agreement subject to ongoing Virginia litigation
Defendants argue their communications to Harris County Constable merely informed of pending receivership, not obstruction
Settlement agreement stipulates Virginia as proper venue for all disputes regarding the judgment
Plaintiffs delayed 45 days before requesting writ of execution after stay lifted in November 2024
Defendants seek stay or $100,000 security bond pending resolution of receiver appointment issues

Stage 2

Core — Entities, Events, Claims

23 nodes

ENT-001

Entity

Atlantic Wave Holdings, LLC

Plaintiff and judgment creditor seeking to enforce Virginia judgment in Texas court

Page 1 — ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC, Plaintiff/Judgment-Creditor

ENT-002

Entity

Secure Community, LLC

Co-plaintiff and judgment creditor alongside Atlantic Wave Holdings

Page 1 — ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC, Plaintiff/Judgment-Creditor

ENT-003

Entity

Cyberlux Corporation

Defendant and judgment debtor opposing enforcement and receivership appointment

Page 1 — CYBERLUX CORPORATION and MARK D. SCHMIDT, Individually, Defendant/Judgment Debtors

ENT-004

Entity

Mark D. Schmidt

Individual defendant and judgment debtor alongside Cyberlux Corporation

Page 1 — CYBERLUX CORPORATION and MARK D. SCHMIDT, Individually, Defendant/Judgment Debtors

ENT-005

Entity

Robert Berleth

Proposed court-appointed receiver who filed oath before formal appointment order

Page 3 — On January 17, 2025, Robert Berleth filed an Oath of Receiver even though the Court had not yet signed its order appointing a receiver. Confusingly, Berleth-who is supposed to be a court-appointed neutral-has already submitted a request on behalf of Atlantic Wave urging his appointment through a written order.

ENT-006

Entity

Thompson Coburn LLP

Law firm representing defendants Cyberlux Corporation and Mark D. Schmidt

Page 7 — THOMPSON COBURN LLP 2100 Ross Avenue, Suite 3200 Dallas, Texas 75201 Tel Phone: (972) 629-7100 Fax: (972) 629-7171 kclark@thompsoncoburn.com apennetti@thompsoncoburn.com COUNSEL FOR DEFENDANTS

ENT-007

Entity

Harris County Constable

County enforcement official contacted regarding writ of execution and receiver appointment

Page 3 — On January 24, 2025, the Harris County Constable's office contacted the undersigned. On February 3, 2025, the undersigned responded to the Harris County Constable's office and provided (1) a copy of the Oath of Receiver filed by Mr. Berleth; (2) an excerpt of the January 16, 2025 hearing transcript highlighting the Court's indication that a receiver would be appointed

EVT-001

Event

Filing of UEFJA Action

Plaintiffs filed action in Texas pursuant to Uniform Enforcement of Foreign Judgments Act on July 30, 2024

Page 2 — On July 30, 2024, Plaintiffs filed this action pursuant to the Texas UEFJA. Plaintiffs contend the filing alone domesticated the Virginia Judgment immediately under the applicable statutory authority.

EVT-002

Event

October 28, 2024 Stay Hearing

Court heard Cyberlux's request for stay of enforcement and granted thirty-day stay

Page 2 — This Court heard that request on October 28, 2024, and granted a thirty-day stay of enforcement. The Court's automatic stay was lifted after thirty days, and the Court declined Cyberlux's request to extend the stay.

EVT-003

Event

Writ of Execution Request

Plaintiffs requested writ of execution on January 2, 2025, approximately 45 days after stay lifted

Page 2 — Even though the stay of this action was lifted at the end of November, Plaintiffs did not request a writ of execution for almost forty five days, waiting until January 2, 2025.

EVT-004

Event

Filing of Receiver Application

Plaintiffs filed Application for Turnover After Judgment and for Appointment of Receiver on January 9, 2025

Page 2 — For an unknown reason, exactly one week later and before the writ of execution was even issued (and before the Harris County Constable even knew about this action), Plaintiffs filed their Application for Turnover After Judgment and for Appointment of Receiver (the "Application"). Plaintiffs' Application was filed on January 9, 2025.

EVT-005

Event

January 16, 2025 Receiver Hearing

Court held hearing on receiver application and indicated it would appoint a receiver, directing parties to confer on order language

Page 2 — On January 16, 2025, the Court held a hearing on Plaintiffs' Application and indicated that the Court would appoint a receiver. Because the parties were still disputing the scope of the receivership order when the hearing concluded, the Court directed the parties to confer and submit an agreed order or two competing orders.

EVT-006

Event

Premature Receiver Oath Filing

Robert Berleth filed Oath of Receiver on January 17, 2025, before court signed appointment order

Page 3 — On January 17, 2025, Robert Berleth filed an Oath of Receiver even though the Court had not yet signed its order appointing a receiver.

EVT-007

Event

Competing Orders Submission

Parties submitted competing receivership orders, with Atlantic Wave submitting January 20 and Cyberlux January 21, 2025

Page 3 — The parties could not agree and submitted their competing orders, Atlantic Wave submitting to the Court on January 20, 2025 before Cyberlux could even provide its input. Cyberlux submitted its competing order on January 21, 2025.

EVT-008

Event

Harris County Constable Contact

Harris County Constable contacted defense counsel on January 24, 2025; defense responded February 3 with receiver documentation

EVT-009

Event

Virginia Emergency Motion Filing

Cyberlux requested emergency hearing in Virginia on January 29, 2025 seeking clarification on judgment and settlement status

Page 4 — Last week on January 29, 2025, Cyberlux requested a hearing in Virginia requesting guidance from the Court and clarification on the status of the judgment and settlement given the ongoing litigation in Virginia, Texas, and California.

EVT-010

Event

Atlantic Wave Blocks Virginia Hearing

Atlantic Wave objected to Virginia emergency hearing dates, claiming insufficient notice and unavailability

Page 4, 5 — Atlantic Wave objected to holding the hearing on February 5 because "the notice provided last week [was] insufficient" and, in that correspondence, Atlantic Wave indicated that an evidentiary hearing was appropriate. That same day, Cyberlux asked for the Court's availability to hold an evidentiary hearing on Friday, February 7, 2025. Atlantic Wave indicated it was not available. The Court then offered availability for every day during the week of February 10. Atlantic Wave did not offer its availability. When Cyberlux offered its availability, Atlantic Wave objected to every day that Cyberlux was available. Atlantic Wave indicated that the hearing could not occur until after February 14, yet it did not offer any dates on which it was available.

EVT-011

Event

Emergency Hearing Request Filing

Plaintiffs filed Request for Emergency Hearing in Texas court on February 5, 2025

Page 3 — On February 5, 2025, Plaintiffs filed their Request for Emergency Hearing.

CLM-001

Claim

UEFJA Immediate Domestication Claim

Plaintiffs contend that filing UEFJA action alone immediately domesticated Virginia judgment under applicable statutory authority

Page 2 — Plaintiffs contend the filing alone domesticated the Virginia Judgment immediately under the applicable statutory authority.

CLM-002

Claim

Settlement Agreement Jurisdiction Defense

Defense claims case is unique because Virginia judgment is part of settlement agreement subject to ongoing Virginia litigation, with settlement requiring Virginia court adjudication

Page 2 — While in many cases this may be true, this particular case is unique because the Virginia Judgment is part and parcel of the parties' Settlement Agreement and, moreover, because the parties' Settlement Agreement-and therefore the Virginia Judgment-are subject to ongoing litigation in Virginia. In the Settlement Agreement, the parties stipulated that all such disputes must be adjudicated in Virginia. Further, the Settlement Agreement provides that a Virginia court is to construe the Settlement Agreement and Judgment to determine whether a breach of the Settlement Agreement has occurred, and such a determination is required before the Virginia Judgment may be enforced.

CLM-003

Claim

No Interference with Constable Claim

Defense asserts communications to Harris County Constable did not interfere with execution but merely informed of pending receiver appointment

Page 5 — Plaintiffs argue Cyberlux's communications to the Harris County Constable have "interfered with service" and that Cyberlux has been "making representations about Judgment Creditor's authority to act on a writ of execution." That is nonsense. Not only does nothing in the undersigned's correspondence to the Harris County Constable not give such directive, but also it defies logic to have a constable executing a writ to locate and seize the same exact property that the Court indicated the receiver would be appointed to locate and over which to take custody.

CLM-004

Claim

Receiver Obviates Writ Claim

Defense claims court's indication to appoint receiver made writ of execution unnecessary and redundant

Page 5 — it defies logic to have a constable executing a writ to locate and seize the same exact property that the Court indicated the receiver would be appointed to locate and over which to take custody

CLM-005

Claim

Jurisdictional Forum Shopping Allegation

Defense alleges Atlantic Wave is obstructing Virginia proceedings while demanding emergency relief in Texas to manipulate court processes

Page 1 — Atlantic Wave's Request for Emergency Hearing uses snippets of correspondence to try and create an issue that does not exist. Notably, despite demanding an emergency hearing in Texas, Plaintiffs are currently opposing the setting of a hearing on an emergent nature brought by Cyberlux, in Virginia. This illustrates Plaintiffs' request to this Court is nothing more than an effort to coerce the Court to forego reviewing the parties' competing orders

Stage 3

In Situ — Quotations, Tells, Tensions, Questions

5 nodes

QUO-001

Quotation

Virginia Court Insufficient Notice Objection

Atlantic Wave objected to Virginia emergency hearing citing insufficient notice from prior week

Page 4 — Atlantic Wave objected to holding the hearing on February 5 because "the notice provided last week [was] insufficient"

TEN-001

Tension

Receiver Neutrality Concern

Proposed receiver filed oath and advocated for plaintiffs before formal appointment, raising neutrality questions

TEN-002

Tension

Contradictory Emergency Posture

Atlantic Wave demands Texas emergency hearing while blocking Virginia emergency hearing on same underlying issues

Page 1, 5 — Notably, despite demanding an emergency hearing in Texas, Plaintiffs are currently opposing the setting of a hearing on an emergent nature brought by Cyberlux, in Virginia. Atlantic Wave is on the one hand obstructing Cyberlux's efforts to get a hearing in Virginia, the proper venue set forth in the Settlement Agreement (and which this Court has repeatedly expressed interest in gaining an understanding of the Virginia courts' position on the parties dispute) while, on the other hand, telling this Court that the sky is falling because no progress is being made in Virginia.

QST-001

Question

Timing of Receiver Application

Why did plaintiffs file receiver application one week after requesting writ of execution and before writ was even issued?

QST-002

Question

Settlement Agreement Breach Determination

Has Virginia court determined whether breach of settlement agreement occurred as required before enforcement?

Page 2 — the Settlement Agreement provides that a Virginia court is to construe the Settlement Agreement and Judgment to determine whether a breach of the Settlement Agreement has occurred, and such a determination is required before the Virginia Judgment may be enforced

Stage 4

Interpretive — Inferences, Omissions, Patterns

5 nodes

INF-001

Inference

Plaintiff Collection Strategy Shift

Plaintiffs' 45-day delay after stay lifted followed by rapid shift from writ to receiver suggests evolving collection strategy or discovery of new asset information

Page 2 — Even though the stay of this action was lifted at the end of November, Plaintiffs did not request a writ of execution for almost forty five days, waiting until January 2, 2025. For an unknown reason, exactly one week later and before the writ of execution was even issued (and before the Harris County Constable even knew about this action), Plaintiffs filed their Application for Turnover After Judgment and for Appointment of Receiver

INF-002

Inference

Dual Enforcement Mechanism Conflict

Simultaneous pursuit of writ execution and receiver appointment creates procedural redundancy and potential conflict over same assets

OMI-001

Omission

Virginia Litigation Substance Absent

Document references ongoing Virginia litigation multiple times but provides no detail on specific issues, claims, or procedural status of that litigation

Page 2, 4 — the parties' Settlement Agreement-and therefore the Virginia Judgment-are subject to ongoing litigation in Virginia. Last week on January 29, 2025, Cyberlux requested a hearing in Virginia requesting guidance from the Court and clarification on the status of the judgment and settlement given the ongoing litigation in Virginia, Texas, and California.

OMI-002

Omission

Settlement Agreement Terms Not Disclosed

Document references settlement agreement provisions regarding venue and breach determination but does not quote or attach the actual agreement

Page 2 — In the Settlement Agreement, the parties stipulated that all such disputes must be adjudicated in Virginia. Further, the Settlement Agreement provides that a Virginia court is to construe the Settlement Agreement and Judgment to determine whether a breach of the Settlement Agreement has occurred

OMI-003

Omission

Writ Issuance Date Uncertainty

Document states writ was issued January 15, 2025 but provides no detail on actual service or execution attempts

Page 2 — According to the Court's records, the writ of execution was issued on January 15, 2025.

Extracted text

9 pages · 13589 characters

Filing Header

CAUSE NO. 2024-48085

ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC,

§ §

IN THE DISTRICT COURT OF

Plaintiff/Judgment-Creditor

§ § HARRIS COUNTY, TEXAS

CYBERLUX CORPORATION and

MARK D. SCHMIDT, Individually,

§ § § Defendant/Judgment Debtors.

§ 129th JUDICIAL DISTRICT

DEFENDANTS' RESPONSE TO PLAINTIFFS' FEBRUARY 5, 2025 REQUEST FOR EMERGENCY HEARING

Atlantic Wave's1 Request for Emergency Hearing uses snippets of correspondence to try and create an issue that does not exist.

Notably, despite demanding an emergency hearing in Texas, Plaintiffs are currently opposing the setting of a hearing on an emergent nature brought by Cyberlux, in Virginia.2 This illustrates Plaintiffs' request to this Court is nothing more than an effort to coerce the Court to forego reviewing the parties' competing orders, refuse Cyberlux's request for hearing on Cyberlux's pending Emergency Motion to Stay, or in the Alternative, Motion to Set Amount of Security to Suspend, Turnover and Appointment of Receiver, and Motion Set Bond for Receiver ("Motion to Stay or Set Bond"), and enter Plaintiffs' overbroad order appointing a receiver. Atlantic Wave's efforts to obfuscate this matter at every turn should not be entertained, and Plaintiffs request for emergency hearing should be refused.

"Atlantic Wave" refers to Plaintiffs Atlantic Wave Holdings, LLC and Secure Community, LLC.

See Exhibit A (e-mail correspondence between counsel for Cyberlux and counsel for Atlantic Wave).

RELEVANT BACKGROUND

On July 30, 2024, Plaintiffs filed this action pursuant to the Texas UEFJA. Plaintiffs contend the filing alone domesticated the Virginia Judgment immediately under the applicable statutory authority. While in many cases this may be true, this particular case is unique because the Virginia Judgment is part and parcel of the parties' Settlement Agreement and, moreover, because the parties' Settlement Agreement-and therefore the Virginia Judgment-are subject to ongoing litigation in Virginia.3 Because of this, Cyberlux requested a stay of enforcement. This Court heard that request on October 28, 2024, and granted a thirty-day stay of enforcement. The Court's automatic stay was lifted after thirty days, and the Court declined Cyberlux's request to extend the stay.

Even though the stay of this action was lifted at the end of November, Plaintiffs did not request a writ of execution for almost forty five days, waiting until January 2, 2025. For an unknown reason, exactly one week later and before the writ of execution was even issued (and before the Harris County Constable even knew about this action), Plaintiffs filed their Application for Turnover After Judgment and for Appointment of Receiver (the "Application").

Plaintiffs' Application was filed on January 9, 2025. According to the Court's records, the writ of execution was issued on January 15, 2025.

On January 16, 2025, the Court held a hearing on Plaintiffs' Application and indicated that the Court would appoint a receiver. Because the parties were still disputing the scope of the receivership order when the hearing concluded, the Court directed the parties to confer and submit

In the Settlement Agreement, the parties stipulated that all such disputes must be adjudicated in Virginia. Further, the Settlement Agreement provides that a Virginia court is to construe the Settlement Agreement and Judgment to determine whether a breach of the Settlement Agreement has occurred, and such a determination is required before the Virginia Judgment may be enforced.

an agreed order or two competing orders. On January 17, 2025, Robert Berleth filed an Oath of Receiver even though the Court had not yet signed its order appointing a receiver.4

The parties could not agree and submitted their competing orders, Atlantic Wave submitting to the Court on January 20, 2025 before Cyberlux could even provide its input. Cyberlux submitted its competing order on January 21, 2025.

On January 24, 2025, the Harris County Constable's office contacted the undersigned. On February 3, 2025, the undersigned responded to the Harris County Constable's office and provided (1) a copy of the Oath of Receiver filed by Mr. Berleth; (2) an excerpt of the January 16, 2025 hearing transcript highlighting the Court's indication that a receiver would be appointed; (3) the Declaration of Charles Watts; and (4) the Declaration of United States Air Force Major General (ret.) Cameron G. Holt.5 On February 5, 2025, Plaintiffs filed their Request for Emergency Hearing.

ARGUMENT

Despite demanding an emergency hearing in Texas, Atlantic Wave is currently telling the Virginia Court it is "not available" for an emergency hearing.

Plaintiffs' Request for Emergency Hearing should be rejected out of hand because there is not an emergency. If there Was something emergent affecting Plaintiffs, Plaintiffs would not currently be opposing Cyberlux's request for hearing before a Virginia court. In fact, that Virginia court offered the parties seven different dates on which an emergency motion could be heard, including:

Tuesday, Feb. 4,

Confusingly, Berleth-who is supposed to be a court-appointed neutral-has already submitted a request on behalf of Atlantic Wave urging his appointment through a written order.

A copy of the e-mail correspondence is attached as Exhibit B. Copies of the documents attached to the e-mail correspondence are attached as Exhibits C-F.

The undersigned and Deputy Constable Montgomery of the Harris County Constable's office have exchanged telephone calls but have not spoken directly.

· Wednesday Feb. 5

· Monday Feb. 10

· Tuesday Feb. 11

· Wednesday Feb. 12

· Thursday Feb. 13

· Friday Feb. 146

Last week on January 29, 2025, Cyberlux requested a hearing in Virginia requesting guidance from the Court and clarification on the status of the judgment and settlement given the ongoing litigation in Virginia, Texas, and California.7

That day, the Virginia court informed the parties that the Court could hold an emergency

availability and instead demanded information. On February 3, Cyberlux attempted to confirm the hearing, offering to have the hearing in person or over videoconference.8 Atlantic Wave objected to holding the hearing on February 5 because "the notice provided last week [was] insufficient" and, in that correspondence, Atlantic Wave indicated that an evidentiary hearing was appropriate.9

That same day, Cyberlux asked for the Court's availability to hold an evidentiary hearing on Friday, February 7, 2025.10 Atlantic Wave indicated it was not available.11

The Court then offered availability for every day during the week of February 10. Atlantic Wave did not offer its availability. When Cyberlux offered its availability, Atlantic Wave objected to every day that Cyberlux was available.12 Atlantic Wave indicated that the hearing could not occur until after February 14, yet it did not offer any dates on which it was available.

Exhibit A (Jan. 29 email from R. Tillery, Feb. 4 email from R. Tillery).

Id.

Exhibit A (Feb. 4 email from F. Zablah to J. Robinson).

Id. (Feb. 4 email from J. Robinson to F. Zablah).

Id. (Feb. 4 email from F. Zablah to J. Robinson).

Id.

Simply put, Atlantic Wave is on the one hand obstructing Cyberlux's efforts to get a hearing in Virginia, the proper venue set forth in the Settlement Agreement (and which this Court has repeatedly expressed interest in gaining an understanding of the Virginia courts' position on the parties dispute) while, on the other hand, telling this Court that the sky is falling because no progress is being made in Virginia. Atlantic Wave should not be permitted to continue its efforts to dupe this Court as to why and how the delays in Virginia have occurred. Plaintiffs' request for emergency hearing should not be entertained unless the Court will also address Cyberlux's Motion to Stay or Set Bond for the receiver.

2. Plaintiffs' conduct, not Cyberlux's conduct, obviated the need for the Harris County Constable to execute the writ.

Plaintiffs argue Cyberlux's communications to the Harris County Constable have "interfered with service" and that Cyberlux has been "making representations about Judgment Creditor's authority to act on a writ of execution." That is nonsense. Not only does nothing in the undersigned's correspondence to the Harris County Constable not give such directive, but also it defies logic to have a constable executing a writ to locate and seize the same exact property that the Court indicated the receiver would be appointed to locate and over which to take custody.

It is especially difficult to understand Atlantic Wave's suggestion that Cyberlux has given the Harris County Constable's office the excerpt of the 4-hour hearing's transcript in which the Court expressly stated it would appoint a receiver in this case. In any event, if the Harris County Constable's office disagrees with the Court's directive, the Harris County Constable is free to seek this Court's guidance on the matter.

Atlantic Wave could-and perhaps should-have sought a writ of execution earlier. They did not. When Atlantic Wave finally decided to seek a writ of execution, it almost immediately

changed its mind, filing its Application and seeking a receiver instead. This Court has indicated it would appoint a receiver (giving Atlantic Wave exactly what it asked for), and the parties have submitted competing orders for the Court's consideration. There is no basis for Atlantic Wave to say that Cyberlux has interfered with its collection efforts by informing the Harris County Constable about the receiver, so this Court should reject Atlantic Wave's request unless Atlantic Wave no longer wishes to proceed with the appointment of the receiver.

CONCLUSION

WHEREFORE PREMISES CONSIDERED, Defendants respectfully request the Court hold an emergency hearing on Defendants' Emergency Motion to Stay, or in the Alternative, Motion to Set Amount of Security to Suspend, Turnover and Appointment of Receiver, and Motion Set Bond for Receiver; issue a stay of the Court's Proposed Order granting turnover and appointing receiver, or alternatively, suspend said Proposed Order upon payment of a security bond in the amount of $100,000.00; 13 and suspend the Proposed Order until the Court determines the appropriate amount of the potential receiver's bond payable to Defendants and orders that Plaintiffs file such bond. Defendants further request any such relief at law or in equity to which Defendants are entitled.

Inofficial Copy Officeof nerd force S' District Comes

The proposed receiver has offered to post such a bond.

Dated: February 7, 2025

Respectfully submitted,

By: /s/ Alexander J. Pennetti Katharine Battaia Clark State Bar No. 24046712 Alexander J. Pennetti State Bar No. 24110208 THOMPSON COBURN LLP 2100 Ross Avenue, Suite 3200 Dallas, Texas 75201 Tel Phone: (972) 629-7100 Fax: (972) 629-7171 kclark@thompsoncoburn.com apennetti@thompsoncoburn.com

COUNSEL FOR DEFENDANTS

Unofficial Copy Office of Marilyn Burgess Lasdos Con Ciao

CERTIFICATE OF SERVICE

I certify that on February 7, 2025, I had this document served on all counsel of record via electronic service.

/s/ Alexander J. Pennetti Alexander James Pennetti

Unofficial Copy Office of Marilyn Burgess District Clerk

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.

Frankie Huff on behalf of Katherine Clark Bar No. 24046712 fhuff@thompsoncoburn.com Envelope ID: 97103416 Filing Code Description: No Fee Documents Filing Description: Defs Response to Plfs Request for Emergency Hearing Status as of 2/7/2025 3:22 PM CST

Case Contacts

Name

BarNumber

TimestampSubmitted

Status

Sandra Meiners

smeiners@thompsoncoburn.com

2/7/2025 9:29:07 AM

SENT

Travis Vargo

tvargo@vargolawfirm.com

2/7/2025 9:29:07 AM

SENT

Micah Jackson

mjackson@berlethlaw.com

2/7/2025 9:29:07 AM

SENT

Laurie DeBardeleben

Idebardeleben@thompsoncoburn.com

2/7/2025 9:29:07 AM

SENT

Roxanna Lock

rlock@thompsoncoburn.com

2/7/2025 9:29:07 AM

SENT

Shawn Grady

shawn@gradycollectionlaw.com

2/7/2025 9:29:07 AM

SENT

Shawn Grady

shawn@gradycollectionlaw.com

2/7/2025 9:29:07 AM

SENT

Jeff Brown

jbrown@thompsoncoburn.com

2/7/2025 9:29:07 AM

SENT

Bernadette Martin

bernadette@gradycollectionlaw.com

2/7/2025 9:29:07 AM

SENT

Lena Brasher

Ibrasher@thompsoncoburn.com

2/7/2025 9:29:07 AM

SENT

Sheli Davis

sdavis@berlethlaw.com

2/7/2025 9:29:07 AM

SENT

Tristian Harris

Cop

tharris@berlethlaw.com

2/7/2025 9:29:07 AM

SENT

Corinne Martin

cmartin@berlethlaw.com

2/7/2025 9:29:07 AM

SENT

Frankie Huff

fhuff@thompsoncoburn.com

2/7/2025 9:29:07 AM

SENT

Michael Poynter

mpoynter@vargolawfirm.com

2/7/2025 9:29:07 AM

SENT

Hannah Fischer Enokicial

hfischer@thompsoncoburn.com

2/7/2025 9:29:07 AM

SENT

Bernadette Martin

bernadette@gradycollectionlaw.com

2/7/2025 9:29:07 AM

SENT

Jocelin A. Tapia

jtapia@thompsoncoburn.com

2/7/2025 9:29:07 AM

SENT

Katharine Clark

kclark@thompsoncoburn.com

2/7/2025 9:29:07 AM

SENT

Alex Pennetti

apennetti@thompsoncoburn.com

2/7/2025 9:29:07 AM

SENT

Edward W.Gray, Jr.

EGray@thompsoncoburn.com

2/7/2025 9:29:07 AM

SENT

Original source file

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File: aw-harris-awh-2024-48085-doc-118855057.pdf
Source UID: source:101d35f7b8de904db7ca4bf6513aa473658645be5da006a9836231f7255e5aef
Full SHA-256: 101d35f7b8de904db7ca4bf6513aa473658645be5da006a9836231f7255e5aef

DISTIL analysis

Extracted text

Defendants' Response to Plaintiffs' February 5, 2025 Request for Emergency Hearing — Formatted Extract

Original source file