January 2025 Vargo–Pennetti–Clark exchange — provisional payoff and disputed scheduling
Original sourceArchived counsel email chain with June5 filing/service wrapper; attributed negotiation and scheduling statements, not a complete ledger or court order.
Each card carries the governed distillate name from the database. Open the quoted anchor before relying on the interpretation.
claimallegation
The nine-page June5,2025 filed Exhibit2 preserves a January17–28 counsel chain, archived June5 at9:32:05AM. The filing envelope101664202 is
The nine-page June5,2025 filed Exhibit2 preserves a January17–28 counsel chain, archived June5 at9:32:05AM. The filing envelope101664202 is submitted June5 at12:13:55PM; e-service status is reported at3:44PM CST. Outer archive receipt/sent times and quoted local message times differ and are not converted without a stated timezone.
Read the anchor · page 1
EXHIBIT 2
6/5/2025 12:13 PM
Marilyn Burgess - District Clerk Harris County
Envelope No. 101664202
By: Shanelle Taylor
Filed: 6/5/2025 12:13 PM
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
claimallegation
Vargo’s January28 message supplies a provisional payoff based on documents seen, excluding collection fees/costs he says remain substantial.
Vargo’s January28 message supplies a provisional payoff based on documents seen, excluding collection fees/costs he says remain substantial. He expressly says he must investigate, declare/support that number and confirm the spreadsheet with his client. He asks for evidence of additional payments to discuss proper credits. This qualifies completeness of his account rather than proving no credit was ever applied.
Read the anchor · page 2
Archived: Thursday, June 5, 2025 9:32:05 AM
From: Travis Vargo
Mail received time: Tue, 28 Jan 2025 21:42:20
Sent: Tue, 28 Jan 2025 21:41:56
To: Pennetti, Alex Clark, Katharine B.
Cc: 'shawn@gradycollectionlaw.com'
Subject: RE: Order
Importance: Normal
Sensitivity: None
Attachments:
Payoff Cyberlux v 2.xlsx;
RECEIVED FROM EXTERNAL SENDER - USE CAUTION
See attached.
Travis B. Vargo
Vargo Law Firm, PC
(713) 524-2441 - Office
From: Travis Vargo
Sent: Tuesday, January 28, 2025 3:41 PM
To: Pennetti, Alex <APennetti@thompsoncoburn.com>; Clark, Katharine B. <KClark@thompsoncoburn.com>
Cc: 'shawn@gradycollectionlaw.com' <shawn@gradycollectionlaw.com>
Subject: RE: Order
Alex,
Here is a pay-off that I prepared based on documents that I’ve seen. This does not include collection fees and costs
that my client is entitled to under the settlement agreement, which I understand to be a substantial sum. Obviously, I
need to investigate this number, declare it, and provide support for it. I also need to confirm this spreadsheet with my
client. In the meantime, please let me know your thoughts. If your client made payments that are not shown on tab 2,
please send me evidence of the payment so that I can discuss it with my client and provide proper credit, if applicable.
Yes, provide dates for the court ordered depositions please.
I don’t have authority to move a court ordered deadline. My client also opposes in light of your client’s continued filings
that necessitate responses from my firm.
Travis B. Vargo
Vargo Law Firm, PC
(713) 524-2441 - Office
From: Pennetti, Alex <APennetti@thompsoncoburn.com>
Sent: Tuesday, January 28, 2025 3:03 PM
To: Travis Vargo <tvargo@vargolawfirm.com>; Clark, Katharine B. <KClark@thompsoncoburn.com>
Cc: 'shawn@gradycollectionlaw.com' <shawn@gradycollectionlaw.com>
Subject: RE: Order
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
claimallegation
Pennetti seeks a payoff letter and supporting history to test disputed amounts and says depositions of Welter, Peterson and Keithly may be u
Pennetti seeks a payoff letter and supporting history to test disputed amounts and says depositions of Welter, Peterson and Keithly may be unnecessary if adequate records arrive. He also seeks coordination of three court-ordered witnesses and asks for discovery extension through February7. Vargo says he cannot move a court-ordered deadline and his client opposes an extension; the correspondence supplies no granted extension.
Read the anchor · page 2
Archived: Thursday, June 5, 2025 9:32:05 AM
From: Travis Vargo
Mail received time: Tue, 28 Jan 2025 21:42:20
Sent: Tue, 28 Jan 2025 21:41:56
To: Pennetti, Alex Clark, Katharine B.
Cc: 'shawn@gradycollectionlaw.com'
Subject: RE: Order
Importance: Normal
Sensitivity: None
Attachments:
Payoff Cyberlux v 2.xlsx;
RECEIVED FROM EXTERNAL SENDER - USE CAUTION
See attached.
Travis B. Vargo
Vargo Law Firm, PC
(713) 524-2441 - Office
From: Travis Vargo
Sent: Tuesday, January 28, 2025 3:41 PM
To: Pennetti, Alex <APennetti@thompsoncoburn.com>; Clark, Katharine B. <KClark@thompsoncoburn.com>
Cc: 'shawn@gradycollectionlaw.com' <shawn@gradycollectionlaw.com>
Subject: RE: Order
Alex,
Here is a pay-off that I prepared based on documents that I’ve seen. This does not include collection fees and costs
that my client is entitled to under the settlement agreement, which I understand to be a substantial sum. Obviously, I
need to investigate this number, declare it, and provide support for it. I also need to confirm this spreadsheet with my
client. In the meantime, please let me know your thoughts. If your client made payments that are not shown on tab 2,
please send me evidence of the payment so that I can discuss it with my client and provide proper credit, if applicable.
Yes, provide dates for the court ordered depositions please.
I don’t have authority to move a court ordered deadline. My client also opposes in light of your client’s continued filings
that necessitate responses from my firm.
Travis B. Vargo
Vargo Law Firm, PC
(713) 524-2441 - Office
From: Pennetti, Alex <APennetti@thompsoncoburn.com>
Sent: Tuesday, January 28, 2025 3:03 PM
To: Travis Vargo <tvargo@vargolawfirm.com>; Clark, Katharine B. <KClark@thompsoncoburn.com>
Cc: 'shawn@gradycollectionlaw.com' <shawn@gradycollectionlaw.com>
Subject: RE: Order
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
claimallegation
Vargo proposes January28 Schmidt, January29 Watts and January30 Robinson depositions, requests changes by11AM January20 and later says no re
Vargo proposes January28 Schmidt, January29 Watts and January30 Robinson depositions, requests changes by11AM January20 and later says no response or alternative dates arrived. Clark says January20 was the objection deadline, submits proposed edits at3PM and a letter brief at5:55PM; Vargo’s no-objections statement is timestamped2:55PM that day. Those timestamps qualify any claim that no edits were ever submitted, without making the earlier2:55 statement false.
Read the anchor · page 4
Shanelle Taylor
Lead Clerk, 129th Civil District Court
MARILYN BURGESS, Harris County District Clerk
201 Caroline, Floor 10| Houston, TX 77002
(832) 927-2500
From: Travis Vargo <tvargo@vargolawfirm.com>
Sent: Tuesday, January 28, 2025 11:16 AM
To: Clark, Katharine B. <KClark@thompsoncoburn.com>
Cc: Pennetti, Alex <APennetti@thompsoncoburn.com>; 'shawn@gradycollectionlaw.com' <shawn@gradycollectionlaw.com>;
'Robert Berleth' <rberleth@berlethlaw.com>; Taylor, Shanelle (DCO) <shanelle.taylor@hcdistrictclerk.com>
Subject: RE: Order
Importance: High
[WARNING] This email originated outside HCDCO. DO NOT CLICK links or attachments unless you know the content is
safe.
Alex,
Please provide availability or conflicts for the depositions. Given lawyer calendars, we should not wait any longer to
schedule.
PS - The only lawyers in Texas representing the Judgment Creditors are on this email.
Travis B. Vargo
Vargo Law Firm, PC
(713) 524-2441 - Office
From: Clark, Katharine B. <KClark@thompsoncoburn.com>
Sent: Monday, January 27, 2025 10:44 PM
To: Travis Vargo <tvargo@vargolawfirm.com>
Cc: Pennetti, Alex <APennetti@thompsoncoburn.com>; 'shawn@gradycollectionlaw.com' <shawn@gradycollectionlaw.com>;
'Robert Berleth' <rberleth@berlethlaw.com>; 'shanelle.taylor@hcdistrictclerk.com' <shanelle.taylor@hcdistrictclerk.com>
Subject: Re: Order
Alex will respond, as he has been working on confirming availability of the three witnesses for the depositions
that the court ordered occur within the next few weeks.
We also received word from Virginia that someone else besides you has sought Mr. Robinson’s availability for
the Texas action, and they have given him a different timeline for response than you do below.
From: Travis Vargo <tvargo@vargolawfirm.com>
Sent: Monday, January 27, 2025 5:20:50 PM
To: Clark, Katharine B. <KClark@thompsoncoburn.com>
Cc: Pennetti, Alex <APennetti@thompsoncoburn.com>; 'shawn@gradycollectionlaw.com' <shawn@gradycollectionlaw.com>;
'Robert Berleth' <rberleth@berlethlaw.com>; 'shanelle.taylor@hcdistrictclerk.com' <shanelle.taylor@hcdistrictclerk.com>
Subject: RE: Order
RECEIVED FROM EXTERNAL SENDER - USE CAUTION
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
claimallegation
Clark reports another person sought Robinson’s availability on a different timeline; Vargo says the only Texas lawyers representing judgment
Clark reports another person sought Robinson’s availability on a different timeline; Vargo says the only Texas lawyers representing judgment creditors are on the email. Lead clerk Shanelle Taylor asks removal of court staff from the chain and says law-day hearings must be confirmed with the court before notice. This is a communications boundary, not court approval of either side’s schedule or a finding of misconduct.
Read the anchor · page 3
Hi, Travis.
With the tight timeframe, we need to proceed with the depositions of the three court-ordered witnesses first. I’m working
on those dates, as Katie said. For the other two, as Katie asked, let us know on Mr. Robinson because I’m not clear on
whether we’re trying to coordinate everyone or if you guys want to depose him twice.
Do you have any update on the payoff letter and supporting documentation that we discussed last week? Given the existing
dispute over what is owed, without a payoff letter and supporting documentation, we need to depose Messrs. Welter,
Peterson, and Keithly.
If we need to pursue the depositions of Messrs. Robinson, Watts, Welter, Peterson, and Keithly, perhaps we can schedule a
full week to conduct these. But as you told the Court, the plaintiffs have been crediting amounts received or collected
against the judgment, so I would imagine a payoff history and payoff amount is something that can be provided relatively
easily, which would mean those depositions wouldn’t be necessary.
Also, may we have until next Friday, 2/7, to serve discovery responses?
Best,
Alex Pennetti
apennetti@thompsoncoburn.com
P: 972 629 7168
F: 972 629 7171
Thompson Coburn LLP
2100 Ross Avenue Suite 3200
Dallas, TX 75201
www.thompsoncoburn.com
From: Taylor, Shanelle (DCO) <shanelle.taylor@hcdistrictclerk.com>
Sent: Tuesday, January 28, 2025 11:29 AM
To: 'Travis Vargo' <tvargo@vargolawfirm.com>; Clark, Katharine B. <KClark@thompsoncoburn.com>
Cc: Pennetti, Alex <APennetti@thompsoncoburn.com>; 'shawn@gradycollectionlaw.com' <shawn@gradycollectionlaw.com>;
'Robert Berleth' <rberleth@berlethlaw.com>
Subject: RE: Order
Importance: High
RECEIVED FROM EXTERNAL SENDER - USE CAUTION
Good Morning,
Can you please remove court staff from this email.
Thank you,
**PLEASE CONFIRM ALL LAW DAY HEARINGS ARE SET WITH THE COURT BEFORE YOU FILE
NOTICE**
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
claimallegation
The chain names Payoff Cyberlux v2.xlsx, a proposed order and a letter brief, but their contents are not physically included. PDF inspection
The chain names Payoff Cyberlux v2.xlsx, a proposed order and a letter brief, but their contents are not physically included. PDF inspection finds no embedded attachments. The spreadsheet’s named tab2 payment history cannot be audited from the supplied email text alone.
Read the anchor · page 2
Archived: Thursday, June 5, 2025 9:32:05 AM
From: Travis Vargo
Mail received time: Tue, 28 Jan 2025 21:42:20
Sent: Tue, 28 Jan 2025 21:41:56
To: Pennetti, Alex Clark, Katharine B.
Cc: 'shawn@gradycollectionlaw.com'
Subject: RE: Order
Importance: Normal
Sensitivity: None
Attachments:
Payoff Cyberlux v 2.xlsx;
RECEIVED FROM EXTERNAL SENDER - USE CAUTION
See attached.
Travis B. Vargo
Vargo Law Firm, PC
(713) 524-2441 - Office
From: Travis Vargo
Sent: Tuesday, January 28, 2025 3:41 PM
To: Pennetti, Alex <APennetti@thompsoncoburn.com>; Clark, Katharine B. <KClark@thompsoncoburn.com>
Cc: 'shawn@gradycollectionlaw.com' <shawn@gradycollectionlaw.com>
Subject: RE: Order
Alex,
Here is a pay-off that I prepared based on documents that I’ve seen. This does not include collection fees and costs
that my client is entitled to under the settlement agreement, which I understand to be a substantial sum. Obviously, I
need to investigate this number, declare it, and provide support for it. I also need to confirm this spreadsheet with my
client. In the meantime, please let me know your thoughts. If your client made payments that are not shown on tab 2,
please send me evidence of the payment so that I can discuss it with my client and provide proper credit, if applicable.
Yes, provide dates for the court ordered depositions please.
I don’t have authority to move a court ordered deadline. My client also opposes in light of your client’s continued filings
that necessitate responses from my firm.
Travis B. Vargo
Vargo Law Firm, PC
(713) 524-2441 - Office
From: Pennetti, Alex <APennetti@thompsoncoburn.com>
Sent: Tuesday, January 28, 2025 3:03 PM
To: Travis Vargo <tvargo@vargolawfirm.com>; Clark, Katharine B. <KClark@thompsoncoburn.com>
Cc: 'shawn@gradycollectionlaw.com' <shawn@gradycollectionlaw.com>
Subject: RE: Order
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
claimallegation
The source includes Vargo’s confidentiality/debt-collector notice and automated e-service rows marked SENT for the June5 objection filing. D
The source includes Vargo’s confidentiality/debt-collector notice and automated e-service rows marked SENT for the June5 objection filing. Duplicate contacts appear. SENT status and the later wrapper do not prove every recipient read the January chain, authenticate missing attachments or replace the rules-based service certificate the automated form says is still required.
Read the anchor · page 7
Travis B. Vargo
Vargo Law Firm, PC
12012 Wickchester, Suite 670
Houston, TX 77079
(713) 524-2441 - Office
(832) 779-8838 - Fax
Confidentiality Notice: The contents of this electronic message, and any attachment to it, contain information which may be
confidential and/or privileged. This information is intended only for the addressed recipients and access by anyone else is
unauthorized. If you are not the intended recipient, any disclosure, copying, distribution, or use of this electronic message or its
contents is strictly prohibited and may be unlawful. If you have received this electronic message in error, please immediately reply to
the sender that you have received the message in error, and destroy all copies of it. Further, nothing in the above message is
intended to and does not constitute tax advice. All information transmitted herein should be disclosed to your tax preparer for advice.
Lastly, pursuant to the Fair Debt Collection Practices Act, you are advised that this office is deemed to be a debt collector and any
information obtained may be used for that purpose.
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
entityobservation
Travis B. Vargo
Read the anchor · page 2
Archived: Thursday, June 5, 2025 9:32:05 AM
From: Travis Vargo
Mail received time: Tue, 28 Jan 2025 21:42:20
Sent: Tue, 28 Jan 2025 21:41:56
To: Pennetti, Alex Clark, Katharine B.
Cc: 'shawn@gradycollectionlaw.com'
Subject: RE: Order
Importance: Normal
Sensitivity: None
Attachments:
Payoff Cyberlux v 2.xlsx;
RECEIVED FROM EXTERNAL SENDER - USE CAUTION
See attached.
Travis B. Vargo
Vargo Law Firm, PC
(713) 524-2441 - Office
From: Travis Vargo
Sent: Tuesday, January 28, 2025 3:41 PM
To: Pennetti, Alex <APennetti@thompsoncoburn.com>; Clark, Katharine B. <KClark@thompsoncoburn.com>
Cc: 'shawn@gradycollectionlaw.com' <shawn@gradycollectionlaw.com>
Subject: RE: Order
Alex,
Here is a pay-off that I prepared based on documents that I’ve seen. This does not include collection fees and costs
that my client is entitled to under the settlement agreement, which I understand to be a substantial sum. Obviously, I
need to investigate this number, declare it, and provide support for it. I also need to confirm this spreadsheet with my
client. In the meantime, please let me know your thoughts. If your client made payments that are not shown on tab 2,
please send me evidence of the payment so that I can discuss it with my client and provide proper credit, if applicable.
Yes, provide dates for the court ordered depositions please.
I don’t have authority to move a court ordered deadline. My client also opposes in light of your client’s continued filings
that necessitate responses from my firm.
Travis B. Vargo
Vargo Law Firm, PC
(713) 524-2441 - Office
From: Pennetti, Alex <APennetti@thompsoncoburn.com>
Sent: Tuesday, January 28, 2025 3:03 PM
To: Travis Vargo <tvargo@vargolawfirm.com>; Clark, Katharine B. <KClark@thompsoncoburn.com>
Cc: 'shawn@gradycollectionlaw.com' <shawn@gradycollectionlaw.com>
Subject: RE: Order
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
entityobservation
Alex Pennetti
Read the anchor · page 3
Hi, Travis.
With the tight timeframe, we need to proceed with the depositions of the three court-ordered witnesses first. I’m working
on those dates, as Katie said. For the other two, as Katie asked, let us know on Mr. Robinson because I’m not clear on
whether we’re trying to coordinate everyone or if you guys want to depose him twice.
Do you have any update on the payoff letter and supporting documentation that we discussed last week? Given the existing
dispute over what is owed, without a payoff letter and supporting documentation, we need to depose Messrs. Welter,
Peterson, and Keithly.
If we need to pursue the depositions of Messrs. Robinson, Watts, Welter, Peterson, and Keithly, perhaps we can schedule a
full week to conduct these. But as you told the Court, the plaintiffs have been crediting amounts received or collected
against the judgment, so I would imagine a payoff history and payoff amount is something that can be provided relatively
easily, which would mean those depositions wouldn’t be necessary.
Also, may we have until next Friday, 2/7, to serve discovery responses?
Best,
Alex Pennetti
apennetti@thompsoncoburn.com
P: 972 629 7168
F: 972 629 7171
Thompson Coburn LLP
2100 Ross Avenue Suite 3200
Dallas, TX 75201
www.thompsoncoburn.com
From: Taylor, Shanelle (DCO) <shanelle.taylor@hcdistrictclerk.com>
Sent: Tuesday, January 28, 2025 11:29 AM
To: 'Travis Vargo' <tvargo@vargolawfirm.com>; Clark, Katharine B. <KClark@thompsoncoburn.com>
Cc: Pennetti, Alex <APennetti@thompsoncoburn.com>; 'shawn@gradycollectionlaw.com' <shawn@gradycollectionlaw.com>;
'Robert Berleth' <rberleth@berlethlaw.com>
Subject: RE: Order
Importance: High
RECEIVED FROM EXTERNAL SENDER - USE CAUTION
Good Morning,
Can you please remove court staff from this email.
Thank you,
**PLEASE CONFIRM ALL LAW DAY HEARINGS ARE SET WITH THE COURT BEFORE YOU FILE
NOTICE**
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
entityobservation
Katharine Battaia Clark
Read the anchor · page 5
Katharine,
Below I sought the following depositions per the attached Order:
January 28 (all day) – Mr. Schmidt
January 29 (morning 9am-12pm, I have a hearing at 1:30) – Mr. Watts Jr.
January 30 (all day) – Mr. Robinson
I received no response, no alternative dates, nothing. Please respond or we are going to notice these depositions per
our schedules. If you do not attend, we will seek a show cause.
Thanks.
Travis B. Vargo
Vargo Law Firm, PC
(713) 524-2441 - Office
From: Clark, Katharine B. <KClark@thompsoncoburn.com>
Sent: Monday, January 20, 2025 5:55 PM
To: Travis Vargo <tvargo@vargolawfirm.com>
Cc: Pennetti, Alex <APennetti@thompsoncoburn.com>; 'shawn@gradycollectionlaw.com' <shawn@gradycollectionlaw.com>;
'Robert Berleth' <rberleth@berlethlaw.com>; 'shanelle.taylor@hcdistrictclerk.com' <shanelle.taylor@hcdistrictclerk.com>
Subject: RE: Order
Ms. Taylor –
It was our understanding the Court requested that we present authorities to assist the Court in his review of any proposed
order edits, and so attached is Defendants’ letter brief submitted in support of Defendants’ proposed form of Order, which I
submitted via e-mail earlier today. We will also be filing this on the docket. However, because today is a holiday for our law
firm, we may not have sufficient staff to do so. If we do not file today, we will do so first thing tomorrow morning.
Sincerely,
Katharine Battaia Clark
kclark@thompsoncoburn.com
P: 972 629 7114
F: 972 629 7171
Thompson Coburn LLP
2100 Ross Avenue
Suite 3200
Dallas, TX 75201
www.thompsoncoburn.com
From: Clark, Katharine B.
Sent: Monday, January 20, 2025 3:00 PM
To: Travis Vargo <tvargo@vargolawfirm.com>
Cc: Pennetti, Alex <APennetti@thompsoncoburn.com>; shawn@gradycollectionlaw.com; Robert Berleth
<rberleth@berlethlaw.com>; shanelle.taylor@hcdistrictclerk.com
Subject: RE: Order
Ms. Taylor –
We had noted that our objects were due today, Monday. Attached is the proposed form of order by Defendants, marked with
track changes. We will be filing a letter brief, as well, in support of these proposed changes.
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
entityobservation
Shanelle Taylor
Read the anchor · page 4
Shanelle Taylor
Lead Clerk, 129th Civil District Court
MARILYN BURGESS, Harris County District Clerk
201 Caroline, Floor 10| Houston, TX 77002
(832) 927-2500
From: Travis Vargo <tvargo@vargolawfirm.com>
Sent: Tuesday, January 28, 2025 11:16 AM
To: Clark, Katharine B. <KClark@thompsoncoburn.com>
Cc: Pennetti, Alex <APennetti@thompsoncoburn.com>; 'shawn@gradycollectionlaw.com' <shawn@gradycollectionlaw.com>;
'Robert Berleth' <rberleth@berlethlaw.com>; Taylor, Shanelle (DCO) <shanelle.taylor@hcdistrictclerk.com>
Subject: RE: Order
Importance: High
[WARNING] This email originated outside HCDCO. DO NOT CLICK links or attachments unless you know the content is
safe.
Alex,
Please provide availability or conflicts for the depositions. Given lawyer calendars, we should not wait any longer to
schedule.
PS - The only lawyers in Texas representing the Judgment Creditors are on this email.
Travis B. Vargo
Vargo Law Firm, PC
(713) 524-2441 - Office
From: Clark, Katharine B. <KClark@thompsoncoburn.com>
Sent: Monday, January 27, 2025 10:44 PM
To: Travis Vargo <tvargo@vargolawfirm.com>
Cc: Pennetti, Alex <APennetti@thompsoncoburn.com>; 'shawn@gradycollectionlaw.com' <shawn@gradycollectionlaw.com>;
'Robert Berleth' <rberleth@berlethlaw.com>; 'shanelle.taylor@hcdistrictclerk.com' <shanelle.taylor@hcdistrictclerk.com>
Subject: Re: Order
Alex will respond, as he has been working on confirming availability of the three witnesses for the depositions
that the court ordered occur within the next few weeks.
We also received word from Virginia that someone else besides you has sought Mr. Robinson’s availability for
the Texas action, and they have given him a different timeline for response than you do below.
From: Travis Vargo <tvargo@vargolawfirm.com>
Sent: Monday, January 27, 2025 5:20:50 PM
To: Clark, Katharine B. <KClark@thompsoncoburn.com>
Cc: Pennetti, Alex <APennetti@thompsoncoburn.com>; 'shawn@gradycollectionlaw.com' <shawn@gradycollectionlaw.com>;
'Robert Berleth' <rberleth@berlethlaw.com>; 'shanelle.taylor@hcdistrictclerk.com' <shanelle.taylor@hcdistrictclerk.com>
Subject: RE: Order
RECEIVED FROM EXTERNAL SENDER - USE CAUTION
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
inferenceinference
The payoff was presented as provisional and incomplete in the author’s own words; treating the spreadsheet as a final verified balance would
The payoff was presented as provisional and incomplete in the author’s own words; treating the spreadsheet as a final verified balance would exceed this record.
inferenceinference
The five-minute sequence between Vargo’s January20 no-edits message and Clark’s edits supports a timing qualification rather than a categori
The five-minute sequence between Vargo’s January20 no-edits message and Clark’s edits supports a timing qualification rather than a categorical accusation of false reporting. The parties’ asserted deadlines also differ.
otherattribution
Complete supplied 9-page source reviewed at SHA-256 8a76c1c83c3c99879564ee77638d5f2061eadfbc9a5a567fb04617d86b04def4. Source assertions, ori
Complete supplied 9-page source reviewed at SHA-256 8a76c1c83c3c99879564ee77638d5f2061eadfbc9a5a567fb04617d86b04def4. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. Exact version_1724dbf7019247b5a031b88f0946668e; SHA256 8a76c1c83c3c99879564ee77638d5f2061eadfbc9a5a567fb04617d86b04def4. All9pages read, material email timing and service-table images checked. PDF attachments inventory empty. Original headers, timezones and source boundaries preserved.
Read the anchor · page 1
EXHIBIT 2
6/5/2025 12:13 PM
Marilyn Burgess - District Clerk Harris County
Envelope No. 101664202
By: Shanelle Taylor
Filed: 6/5/2025 12:13 PM
UnofficialCopyOfficeofMarilynBurgessDistrictClerk
questionquestion
What native spreadsheet, payment evidence and final payoff history resolve the balance and omitted collection costs?
questionquestion
What issued orders, actual notices and deposition/filing records establish the authorised dates and subsequent compliance?
distillateallegation
CONNECT
Reviewed relationships
The canvas follows the database: source to DISTIL record, DISTIL record to knowledge object, then reviewed relationship. Position alone means nothing.
Pennetti seeks a payoff letter and supporting history to test disputed amounts and says depositions of Welter, Peterson and Keithly may be unnecessary if adequate records arrive. He also seeks coordination of three court-ordered witnesses and asks for discovery extension through February7. Vargo says he cannot move a court-ordered deadline and his client opposes an extension; the correspondence supplies no granted extension.supportsWhat issued orders, actual notices and deposition/filing records establish the authorised dates and subsequent compliance?
Specifically named source propositions support the bounded distinction or question.
The chain names Payoff Cyberlux v2.xlsx, a proposed order and a letter brief, but their contents are not physically included. PDF inspection finds no embedded attachments. The spreadsheet’s named tab2 payment history cannot be audited from the supplied email text alone.supportsWhat native spreadsheet, payment evidence and final payoff history resolve the balance and omitted collection costs?
Specifically named source propositions support the bounded distinction or question.
Vargo’s January28 message supplies a provisional payoff based on documents seen, excluding collection fees/costs he says remain substantial. He expressly says he must investigate, declare/support that number and confirm the spreadsheet with his client. He asks for evidence of additional payments to discuss proper credits. This qualifies completeness of his account rather than proving no credit was ever applied.supportsWas Vargo’s payoff presented as a final complete verified balance?
Specifically named source propositions support the bounded distinction or question.
Vargo proposes January28 Schmidt, January29 Watts and January30 Robinson depositions, requests changes by11AM January20 and later says no response or alternative dates arrived. Clark says January20 was the objection deadline, submits proposed edits at3PM and a letter brief at5:55PM; Vargo’s no-objections statement is timestamped2:55PM that day. Those timestamps qualify any claim that no edits were ever submitted, without making the earlier2:55 statement false.supportsWhat issued orders, actual notices and deposition/filing records establish the authorised dates and subsequent compliance?
Specifically named source propositions support the bounded distinction or question.
Vargo’s January28 message supplies a provisional payoff based on documents seen, excluding collection fees/costs he says remain substantial. He expressly says he must investigate, declare/support that number and confirm the spreadsheet with his client. He asks for evidence of additional payments to discuss proper credits. This qualifies completeness of his account rather than proving no credit was ever applied.supportsThe payoff was presented as provisional and incomplete in the author’s own words; treating the spreadsheet as a final verified balance would exceed this record.
Specifically named source propositions support the bounded distinction or question.
Clark reports another person sought Robinson’s availability on a different timeline; Vargo says the only Texas lawyers representing judgment creditors are on the email. Lead clerk Shanelle Taylor asks removal of court staff from the chain and says law-day hearings must be confirmed with the court before notice. This is a communications boundary, not court approval of either side’s schedule or a finding of misconduct.supportsWhat issued orders, actual notices and deposition/filing records establish the authorised dates and subsequent compliance?
Specifically named source propositions support the bounded distinction or question.
The chain names Payoff Cyberlux v2.xlsx, a proposed order and a letter brief, but their contents are not physically included. PDF inspection finds no embedded attachments. The spreadsheet’s named tab2 payment history cannot be audited from the supplied email text alone.supportsWas Vargo’s payoff presented as a final complete verified balance?
Specifically named source propositions support the bounded distinction or question.
The chain names Payoff Cyberlux v2.xlsx, a proposed order and a letter brief, but their contents are not physically included. PDF inspection finds no embedded attachments. The spreadsheet’s named tab2 payment history cannot be audited from the supplied email text alone.supportsThe payoff was presented as provisional and incomplete in the author’s own words; treating the spreadsheet as a final verified balance would exceed this record.
Specifically named source propositions support the bounded distinction or question.
Vargo proposes January28 Schmidt, January29 Watts and January30 Robinson depositions, requests changes by11AM January20 and later says no response or alternative dates arrived. Clark says January20 was the objection deadline, submits proposed edits at3PM and a letter brief at5:55PM; Vargo’s no-objections statement is timestamped2:55PM that day. Those timestamps qualify any claim that no edits were ever submitted, without making the earlier2:55 statement false.supportsThe five-minute sequence between Vargo’s January20 no-edits message and Clark’s edits supports a timing qualification rather than a categorical accusation of false reporting. The parties’ asserted deadlines also differ.
Specifically named source propositions support the bounded distinction or question.
Vargo’s January28 message supplies a provisional payoff based on documents seen, excluding collection fees/costs he says remain substantial. He expressly says he must investigate, declare/support that number and confirm the spreadsheet with his client. He asks for evidence of additional payments to discuss proper credits. This qualifies completeness of his account rather than proving no credit was ever applied.supportsWhat native spreadsheet, payment evidence and final payoff history resolve the balance and omitted collection costs?
Specifically named source propositions support the bounded distinction or question.
WEIGH
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No published WEIGH run
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