The evidence/CXF-S-8A76C1C83C3C

Context source · CXF-S-8A76C1C83C3C

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.
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SHA-256 8a76c1c83c3c99879564…9 pages · 358 KB

DISTILLATES

What the source contains

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.

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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.

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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.

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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.

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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.

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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

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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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%
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.

50%
Confidence 75%Link weight 50%

WEIGH

Explained weighting

A score appears only when its components and change threshold are published.

No published WEIGH run

The active Website Edition contains no applied score snapshot for this source or its connected objects. That means not assessed—not zero.