Motion to Abate in Robert and Jennifer Welch vs. GreenEco Builders, L.L.C.| Trellis.Law

On March 01, 2019 a Motion-Secondary was filed involving a dispute between Welch, Jennifer, Welch, Robert, and Blue Marlin Resources, L.L.C., Greeneco Builders, L.L.C., for Contract - Other in the District Court of Galveston County.

Preview
Filed: 7/15/2020 3:59 PM
JOHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 44553612
By: Shailja Dixit
7/15/2020 4:02 PM
CAUSE NO. 19-CV-0340

ROBERT WELCH AND § IN THE DISTRICT COURT OF
JENNIFER WELCH §
Plaintiffs, §
§ GALVESTON COUNTY, TEXAS
vs. §
§
GREENECO BUILDERS, L.L.C. § 122ND JUDICIAL DISTRICT
Defendant
PLAINTIFFS’ RESPONSE TO THE DEFENDANT’S
MOTION TO ABATE CASE PENDING RE-PURCHASE OR, IN THE
ALTERNATIVE, TO EXTEND ALL DEADLINES AND CONTINUE
TRIAL SETTING

COMES NOW, Robert Welch and Jennifer Welch (“Plaintiffs”), and file this their

Response to the Defendant’s Motion to Abate Case Pending Re-Purchase or, In the

Alternative, to Extend All Deadlines and Continue Trial Setting, and would respectfully

show the Court the following:

Preliminary Statement

1. In a remarkable pleading, Defendant requests the Court to abate this lawsuit

because it has elected to buy Plaintiffs’ home. The statutory provision relied on by

Defendant, however, does not support an abatement and certainly Defendant has not

demonstrated its right to purchase Plaintiffs’ home under that statute. Defendant’s motion

to abate and its motion for continuance join a long list of delay tactics employed by

Defendant in this matter. There is no legal support for abating this lawsuit and this Court

has given Defendant ample opportunity to prepare for trial.
2. This Court should deny Defendant’s motion – just as the Honorable Lonnie

Cox with the 56th Judicial District Court denied an identical motion filed by Greeneco a

week prior to this filing.1

Purchase Election

3. While Defendant notifies this Court of its election to purchase Plaintiffs’

home under §27.0042 of the Texas Property Code, it failed to inform this Court of

additional matters for which Defendant must compensate Plaintiffs in the event of such an

election. §27.0042(c)(2) also requires Defendant to pay attorney’s fees, expert fees,

reimbursements for permanent improvements to the home and the costs to move from the

home.

4. Plaintiffs have already notified Defendant that its election to purchase the

home does not comply with the statute because Defendant offers practically nothing in

compensation to Plaintiffs aside from purchasing the home – another fact Defendant failed

to disclose to the Court.2 Accordingly, even if Defendant has the absolute right to purchase

Plaintiffs’ home, the remaining damage items must still be litigated unless Defendant pays

reasonable value for them.

5. This is Defendant’s second request to abate this lawsuit. The case has already

been delayed substantially by Defendant’s request to perform inspections and to determine

the cause of the defects in the home. Defendant has already inspected the home three times

1
See July 9, 2020 Order, attached hereto as Exhibit A.
2
See June 22, 2020 correspondence from Dax Faubus to M. Cohn, attached hereto as Exhibit B.
2
and presumably will designate experts on their deadline. Defendant has provided no valid

reason to abate this matter and the request should be denied.

Continuance Request

6. Defendant has also failed to provide any valid reason to continuing the trial

date of this matter except for the COVID virus crisis. Obviously, if shut down orders are

still in place, a jury trial cannot be conducted in October. But if that is not the case,

Defendant has provided this Court no reason why a trial should not go forward. As such

Defendant’s motion to continue the case should also be denied.

7. Plaintiffs respectfully request that this Court deny Defendant’s third request

to abate this lawsuit and deny its request for a trial continuance.

Respectfully submitted,

THE FAUBUS FIRM

By: /s/ Dax O. Faubus
Dax O. Faubus
State Bar No. 24010019
1001 Texas Avenue, 11th Floor
Houston, Texas 77002
Telephone: (713) 222-6400
Facsimile: (713) 222-7240
dax-notice@faubusfirm.com

Attorneys for Plaintiffs

3
CERTIFICATE OF SERVICE

I hereby certify that on this 15th day of July 2020, a true and correct copy of the
foregoing pleading was served upon the following counsel of record pursuant to Rule 21
of the Texas Rules of Civil Procedure:

Via E-Mail:
H. Miles Cohn
Joe R. Savoie
Crain, Caton & James
1401 McKinney Street, 17th Floor
Houston, Texas 77010
mcohn@craincaton.com
savoie-efile@craincaton.com

Counsel for Defendant

/s/ Dax O. Faubus
Dax O. Faubus

4
EXHIBIT A
! " # $
()* &

%
- )
& +,
.%/01 &’4? ’
&2 3 3
7 4/ (
&’

&5 6 8
& 9 : ;
-& < =( 7 >79 3 339
& &

. 8 /822@

A B3
C C C

A 3

D2D ! / ;E "

A A A
/08@ ! /D F D 217 F1 @8!D7 /81 D2D ! /%@ 1/81 / G /D @D D !8 H

DIJ7F0 @D 73 8 /0D ./D7 /86D3 / K/D ! .. /D@ ! 1 /8 JD 78 . D//8 H 0D 1J7/3

0 68 H F1 @8!D7D! /0D 1/81 3 L 7D@I1 @D /0D7D/1 ! /0D 7HJ D / 2F1J @D.3 8@ 2/0D 1I8 81

/0 / @JF0 1/81 @01J.! GDH7 M (

3 A B3 /0 /

. C8/0 /0D DKFDI/81 1/D! D.143 /08@ . 4@J8/3 8 F.J H .. I&D /78 . !D ! D@3 8@

G /D! J 8. 2J7/0D7 17!D7 2 /08 1J7/:

0D /78 . 2/ @ . 4@J8/3 FJ77D /.L @D/ 217 F/1GD7 E3 3 8@ !1 /8 JD!: !

1/48/0@/ !8 H /0D 2 7DH18 9 /0D I 7/8D@ LM D I.D !8 H@ 7! 1/81 @3 ! L

/ ND !8 16D7L3 48/0 7@IDF/ / /0D D2D ! %@ D.DF/81 / D IJ7F0 @D /0D . 8 /822@%

IJ7@J / DK @ %71ID7/L 1!D O > P 3 8 F : D . 8 /822@% F. 8 @ J

1!D O > QFR
P
8H D! /08@
S ! L 2 3

M4&:
&

A A ?

7!D7 D L8 H 1/81 217 1 /8 J FD
; EEP
EXHIBIT B
June 22, 2020

Via E-mail: mcohn@craincaton.com
H. Miles Cohn
CRAIN, CATON & JAMES, P.C.
17th Floor, Five Houston Center
1401 McKinney Street
Houston, Texas 77010-4035

Re: Cause No. 19-CV-0340; Robert Welch and Jennifer Welch v. Greeneco Builders,
L.L.C.; In the 122nd Judicial District Court of Galveston County, Texas;

Dear Mr. Cohn:

I write in response to your client’s June 15, 2020 demand to re-purchase my clients’
home pursuant to Texas Property Code §27.004(g).
Unfortunately, your client is not entitled to invoke its contractual right to re-
purchase the home in this circumstance because the home was more than five years old
when your client initially invoked its option on April 3, 2020 and when this lawsuit was
filed on March 1, 2019. Your client finished construction of the home in 2013, about 6
years before its election to re-purchase the home and more than five years before this
lawsuit was filed. §27.0042(b)(1) prohibits such an election if “the residence is more than
five years old at the time an action is initiated.” Both your client’s election and the filing
of my clients’ lawsuit were more than five years after the home was built.
My clients are willing, however, to negotiate with Greeneco for a resolution of this
case in which it purchases the home from my clients. The home has appreciated in value
since it was built so the market value must be paid. I have enclosed a Comparative Market
Analysis supporting the sale price below.
Also, my clients have made several improvements to the home that must be
reimbursed. My clients will need to be paid a reasonable cost to move from their home,
which will include the cost to store their contents for up to six months while they search
for a new home. Moreover, because my clients’ home has substantially elevated mold
levels, the contents may not simply be moved into a new residence. They must first be
cleaned and to the extent they cannot be cleaned, they must be replaced. Such costs are
contemplated by your client’s obligation to pay “reasonable cost” to move from the
Dax O. Faubus, Partner The Faubus Firm • 1001 Texas Ave., 11th Floor • Houston, Texas 77002
Dax-notice@faubusfirm.com Telephone: 713.222.6400 • Facsimile: 713.222.7240 • www.faubusfirm.com
H. Miles Cohn
June 22, 2020
Page -2-

residence.” Finally, your client will pay for the consulting, engineer and attorney’s fees
required to prosecute this matter.
Your letter states that such fees are not recoverable pursuant to Mitchell v. D.R.
Horton-Emerald, Ltd., 579 S.W.3d 135 (Tex.App. – Houston [1st Dist.] 2019, rev. denied
- rehearing requested). Your understanding of the law is wrong. First, my clients have
plead claims separate from the RCLA that entitle them to attorney’s fees. Second, Mitchell
did not concern §27.0042. Instead, the court assessed whether such fees are allowed under
§27.004(g). §27.0042 allows for attorney’s fees separate from the circumstances involved
in Mitchell. The Texas Legislature did not intend to give homebuilders the right to take a
homeowner’s home without first compensating them for the substantial fees and expenses
required by litigation. I certainly will not allow your client to do that here.
We have previously provided you the invoices establishing my clients’ engineering
and consulting fees. (See Plaintiffs’ Response to Request for Disclosure). I have enclosed
a breakdown of the services rendered by my firm in prosecuting this matter and the
reasonable and necessary fees associated with such services.

In summary, your client must pay the items set out below in order to pursue its
election to buy my clients’ home:

Purchase Price: $254,894.88
Closing Costs: Paid by Greeneco at closing
Home Improvements: $16,193.15
Moving Costs: $41,463.32
Attorney’s Fees $32,358.83
Expert Fees: $9,865.50
Total: $354,775.68

I have also enclosed a breakdown of the home improvements and moving costs referenced
above.

Should your client wish to go forward with the purchase of my clients’ home, it
will need to pay the above referenced amounts contemporaneous with the home’s closing.
And should we come to an agreement, the closing is fine to take place within 90 days,
provided that we agree to any extensions necessary due to good faith circumstances of my
clients. Finally, your client must agree to pay all closing costs.

Dax O. Faubus, Partner The Faubus Firm • 1001 Texas Ave., 11th Floor • Houston, Texas 77002
Dax@faubusfirm.com Telephone: 713.222.6400 • Facsimile: 713.222.7240 • www.faubusfirm.com
H. Miles Cohn
June 22, 2020
Page -3-

As always, I am available to discuss any questions or comments you may have.

Very truly yours,
/s/ Dax O. Faubus

Dax O. Faubus

DOF/dlg

cc:
Via E-Mail: Savoie-efile@craincaton.com
Joe R. Savoi

Purchase Price $254,894.88 Home
Improvements

Closing Costs PAID BY New HVAC Unit $7,500.00
GREENECO AT
CLOSING

Home $16,193.15 New Flooring $8,693.15
Improvements

Moving Costs $41,463.32 Total Home $16,193.15
Improvements

Attorney’s Fees $32,358.83

Expert Fees $9,865.50

Total: $354,775.68 Moving Costs

Move Out $2,637.00

Contents Cleaning $27,776.32

Contents $11,050.00
Replacement

Total Moving $41,463.32
Costs

1
Attorney’s Fees
Employee Activity Date Memo/Description Duration Rate Amount
Initial telephone conference with clients concerning case against builder,
Dax O. Faubus 09/28/2018 Greeneco; status conference concerning same. 1.5 $450.00 $675.00
Debra Green 10/09/2018 Prepare and send correspondence to clients. 0.5 $150.00 $75.00
Dax O. Faubus 10/09/2018 Receipt and review client materials and mold lab report from AQ Testing. 1.5 $450.00 $675.00
Debra Green 10/12/2018 Email with clients concerning case documents needed. 0.6 $150.00 $90.00
Debra Green 10/20/2018 Receipt and review signed fee agreement; open new client file. 0.8 $150.00 $112.50
Email with clients concerning inspection by HVAC expert; Receipt and review
Debra Green 11/09/2018 client documents; status conference concerning same. 0.5 $150.00 $75.00
Research Texas Secretary of State for registered agent information for
Debra Green 11/13/2018 Greeneco. 0.5 $150.00 $75.00
Dax O. Faubus 11/14/2018 Review and finalize RCLA notice letter to Greeneco. 1.2 $450.00 $540.00
Debra Green 11/14/2018 Assist attorney in preparing and serving RCLA notice letter to builder. 1.5 $150.00 $225.00
Receipt and review correspondence from opposing counsel regarding
Dax O. Faubus 11/29/2018 inspection. 0.3 $450.00 $135.00
Debra Green 11/30/2018 Email with opposing counsel regarding scheduling inspection. 0.6 $150.00 $90.00
Debra Green 12/04/2018 Receipt and review proposal from DD Mechanical; forward same to clients. 0.5 $150.00 $75.00
Dax O. Faubus 12/04/2018 Receipt and review report from DD Mechanical. 1.3 $450.00 $585.00
Debra Green 12/06/2018 Email with opposing counsel regarding scheduling inspection. 0.6 $150.00 $90.00
Dax O. Faubus 12/07/2018 Receipt and review HVAC report from expert. 0.4 $450.00 $180.00
Angela Petro 12/12/2018 Travel to and attend inspection. 3.0 $100.00 $300.00
Angela Petro 12/13/2018 Travel to and attend inspection. 3.0 $100.00 $300.00
Receipt and review correspondence from opposing counsel in response to
Dax O. Faubus 12/28/2018 RCLA notice letter. 1.2 $450.00 $540.00
Terri Webb 01/13/2019 Prepare Plaintiffs' original petition 0.5 $85.00 $42.50
Debra Green 03/01/2019 Assist attorney in preparing and filing original petition. 1.0 $150.00 $150.00
Dax O. Faubus 03/01/2019 Review and finalize Plaintiffs' original petition. 3.2 $450.00 $1,440.00
Ada I. Ferrer 03/22/2019 Draft first set of Plaintiff's integrated discovery requests. 0.6 $250.00 $158.33
Review the return from the process server. Calculate the answer date. Review
Ada I. Ferrer 03/25/2019 Omnifocus to verify the date was entered. 0.2 $250.00 $41.67
Dax O. Faubus 04/08/2019 Receipt and review Defendant’s original answer and plea in abatement. 1.7 $450.00 $765.00
Dax O. Faubus 04/09/2019 Review and finalize Plaintiff’s first integrated discovery requests to Defendant. 2.3 $450.00 $1,035.00
Ada I. Ferrer 04/16/2019 Discuss the affidavit with the client and revise the same. 0.6 $250.00 $145.83
Draft discovery requests. Review the file. Draft a controverting affidavit and
Ada I. Ferrer 04/16/2019 response to the plea in abatement. 2.5 $250.00 $625.00
Ada I. Ferrer 04/18/2019 Receive and review affidavit from client. 0.3 $250.00 $83.33
Assist attorney in preparing and filing response to motion to abate and
Debra Green 04/18/2019 controverting affidavit. 1.0 $150.00 $150.00
Dax O. Faubus 04/22/2019 Review and finalize Plaintiffs' response to plea in abatement. 2.4 $450.00 $1,080.00
Receipt and review Defendant's response to Plaintiffs’ first integrated discovery
Dax O. Faubus 05/15/2019 requests. 2.3 $450.00 $1,035.00
Ada I. Ferrer 05/22/2019 Review FHA information. 0.3 $250.00 $62.50
Review of discovery responses; conference with D. Faubus, D. Green and A.
Ferrer concerning same; preparation and transmittal of correspondence to
Debbie Pellegrin 05/22/2019 opposing counsel concerning discovery responses. 0.8 $150.00 $120.00
Review and finalize correspondence to opposing counsel regarding discovery
Dax O. Faubus 05/22/2019 responses and motion to compel. 0.5 $450.00 $225.00
Conferences with D. Faubus, D. Green and A. Ferrer re: status conference of
this date; telephone conferences with opposing counsel concerning status
conference of this date; telephone conferences with Court Coordinator
Debbie Pellegrin 05/23/2019 concerning status conference of this Date. 1.0 $150.00 $150.00
Attend status conference; review signed docket control order; status conference
Dax O. Faubus 05/23/2019 concerning same. 2.5 $450.00 $1,125.00
Debra Green 05/24/2019 Received and docketed docket control order. 0.7 $150.00 $105.00
Debbie Pellegrin 05/24/2019 Transmittal of DCO to client and request for additional documents. 0.8 $150.00 $120.00
Dax O. Faubus 05/24/2019 Receipt and review request for oral hearing on Defendant’s plea in abatement. 0.3 $450.00 $135.00
Receipt and review notice of case setting from court; status conference
Dax O. Faubus 05/28/2019 concerning same. 0.3 $450.00 $135.00
Debra Green 05/29/2019 Email with opposing counsel regarding hearing conflict. 0.2 $150.00 $30.00
Dax O. Faubus 05/30/2019 Receipt and review amended notice of hearing. 0.3 $450.00 $135.00
Receipt and respond to email from opposing counsel concerning status
Dax O. Faubus 06/13/2019 conference. 0.3 $450.00 $135.00
Conduct an extensive review of the file to identify and determine statute of
Ada I. Ferrer 06/18/2019 limitations. 0.8 $250.00 $187.50
Dax O. Faubus 06/19/2019 Prepare for and attend hearing on plea in abatement. 2.4 $450.00 $1,080.00
Ada I. Ferrer 06/20/2019 Receive and review the agreed order abating the case. 0.2 $250.00 $41.67
Receipt and review agreed order of abatement; status conference concerning
Dax O. Faubus 06/20/2019 same. 0.4 $450.00 $180.00
Ada I. Ferrer 06/27/2019 Receive, review, and respond to the client's e-mail. 0.3 $250.00 $62.50
Debbie Pellegrin 07/01/2019 Receipt and review of Lauver report. 1.0 $150.00 $150.00
Dax O. Faubus 07/01/2019 Recept and review mold lab report from AQ Testing. 2.3 $450.00 $1,035.00

1
Employee Activity Date Memo/Description Duration Rate Amount
Email with expert and client concerning inspection by building science
Debra Green 07/17/2019 engineer. 0.2 $150.00 $30.00
Debra Green 07/25/2019 Email to opposing counsel regarding list of proposed arbitrators. 0.2 $150.00 $30.00
Email with opposing counsel concerning extension of expert reports; status
Debra Green 09/19/2019 conference concerning same. 0.5 $150.00 $75.00
Process and review Apollo's report. Bates, renamed and saved. Produced to
Jamie A. Diaz 09/25/2019 opposing counsel and sent copy to C. Johnson. 1.0 $100.00 $100.00
Debra Green 09/25/2019 Receipt and review protocol from Linda Lauver; prepare for production. 1.0 $150.00 $150.00
Review and finalize Plaintiffs’ supplemental document production; receipt and
Dax O. Faubus 09/25/2019 review report from expert Reid Middlebrooks. 4.2 $450.00 $1,890.00
Receipt and review protocol from AQ Testing; Review and finalize Plaintiffs'
Dax O. Faubus 09/26/2019 supplemental document production. 2.4 $450.00 $1,080.00
Erika Fernandez 10/07/2019 Assisted attorney in bates labeling client documents. 0.3 $85.00 $25.50
Debra Green 10/08/2019 Conference with expert concerning status of report. 0.2 $150.00 $30.00
Debra Green 10/17/2019 Status conference concerning case strategy and 35 day abatement. 0.2 $150.00 $30.00
Email with court coordinator regarding setting a status conference after 35 day
Debra Green 10/17/2019 abatement. 0.2 $150.00 $30.00
Call with DF and DG re: case. Draft and send letter to opposing counsel re:
Jamie A. Diaz 10/17/2019 inspections. 1.0 $100.00 $100.00
Review and finalize correspondence to opposing counsel concerning additional
Dax O. Faubus 10/17/2019 inspection. 0.4 $450.00 $180.00
Receipt and review reports from Carl Johnson; prepare for production; update
Debra Green 10/20/2019 damage model. 1.0 $150.00 $150.00
Dax O. Faubus 10/20/2019 Receipt and review expert reports from Carl Johnson. 1.8 $450.00 $810.00
Dax O. Faubus 10/21/2019 Review and finalize Plaintiffs' supplemental document production. 1.2 $450.00 $540.00
Debra Green 10/23/2019 Email with clients concerning case documents. 0.6 $150.00 $90.00
Receipt and respond to email from opposing counsel concerning inspection;
Dax O. Faubus 11/01/2019 status conference concerning same. 0.3 $450.00 $135.00
Debra Green 11/13/2019 Status conference concerning status of abatement and next steps. 0.2 $150.00 $30.00
Erika Fernandez 11/13/2019 Attended clients home inspection. 6.0 $85.00 $510.00
Receipt and review correspondence from opposing counsel regarding RCLA;
Dax O. Faubus 11/21/2019 status conference concerning same. 0.5 $450.00 $225.00
Emails with client and call with Mr. Welch re: all case documents pertaining to
Jamie A. Diaz 11/22/2019 the AC work. 0.5 $100.00 $50.00
Assist attorney in preparing and serving correspondence to opposing counsel
Debra Green 11/22/2019 regarding RCLA offer. 0.5 $150.00 $75.00
Review and finalize letter to opposing counsel in response to November 21,
2019 correspondence; review and finalize correspondence to opposing counsel
Dax O. Faubus 11/22/2019 concerning discovery. 1.2 $450.00 $540.00
Assist attorney in preparing and forwarding correspondence to opposing
Debra Green 12/02/2019 counsel. 0.5 $150.00 $75.00
Review and finalize correspondence to opposing counsel concerning discovery
Dax O. Faubus 12/02/2019 extension. 0.4 $450.00 $180.00
Receive the Notice form the court setting status conference. Draft Notice and
Jamie A. Diaz 12/05/2019 filed and emailed to all counsel. 0.5 $100.00 $50.00
Dax O. Faubus 12/05/2019 Receipt and review notice of status conference. 0.3 $450.00 $135.00
Receipt and review Defendant's first amended response to discovery and
Dax O. Faubus 01/07/2020 request for disclosures. 1.8 $450.00 $810.00
Dax O. Faubus 01/30/2020 Receipt, review and sign agreed docket control order. 0.3 $450.00 $135.00
Calendared amended DCO; Emailed to the client and emailed Trial notice to
Jamie A. Diaz 02/03/2020 experts. 1.0 $100.00 $100.00
Dax O. Faubus 04/01/2020 Receipt and review Defendant's request for disclosure. 0.3 $450.00 $135.00
Receipt and review Request for Disclosure from opposing counsel; forward
Jamie A. Diaz 04/02/2020 same to client. 0.3 $100.00 $25.00
Receipt and review email from opposing counsel concerning continuance of
Dax O. Faubus 04/02/2020 trial and deadlines. 0.3 $450.00 $135.00
Receipt and review correspondence from opposing counsel concerning buy-
Dax O. Faubus 04/03/2020 back purchase option; status conference concerning same. 1.3 $450.00 $585.00
Receipt and review letter from opposing counsel re: buy back of home; forward
Jamie A. Diaz 04/06/2020 same to client. 0.3 $100.00 $25.00
Email correspondence with the client re: setting up call with DOF to discuss Ltr
Jamie A. Diaz 04/08/2020 from OC. 0.3 $100.00 $25.00
Respond to opposing counsel’s 04/02/20 email concerning continuance of trial
Dax O. Faubus 04/10/2020 and deadlines. 0.3 $450.00 $135.00
Telephone conference with clients concerning buy-back purchase option letter;
Dax O. Faubus 04/12/2020 status conference concerning same. 1.2 $450.00 $540.00
Dax O. Faubus 04/12/2020 Conduct teleconference with clients re: buy back offer. 0.3 $450.00 $135.00
Status conference concerning builder's buy-back option offer letter; assist
attorney in preparing timesheets, damage model and information to provide
opposing counsel in response to buy-back offer; email with opposing counsel
Debra Green 04/13/2020 notifying him of receipt of letter. 1.0 $150.00 $150.00
Jamie A. Diaz 04/14/2020 Multiple emails with the clients re: contents and requested document by DOF. 0.3 $100.00 $25.00
Jamie A. Diaz 04/15/2020 Email correspondence with the clients re: requested documents by DOF. 0.3 $100.00 $25.00

2
Employee Activity Date Memo/Description Duration Rate Amount
Debra Green 04/17/2020 Update damage model. 1.0 $150.00 $150.00
Review clients documents and confirm we have all necessary documents for
buyback offer; confer with DG re: same; forward contents list to Linda Lauver
Jamie A. Diaz 04/20/2020 for review. 0.3 $100.00 $25.00
Receipt and review email from client re: storage quotes; processed and saved to
Jamie A. Diaz 04/21/2020 clients file. 0.3 $100.00 $25.00
Receipt and review clients' contents list; review case expenses; update damage
Debra Green 04/23/2020 model. 2.0 $150.00 $300.00
Receipt and review revised contents list from L. Lauver; receipt and review
Jamie A. Diaz 04/24/2020 email from G. Aldaco, review CMA and saved for processing. 0.5 $100.00 $50.00
Receipt and review email and invoice from G. Aldaco, saved invoice and
Jamie A. Diaz 04/27/2020 comparative market analysis to file; confer with DOF re: same. 0.5 $100.00 $50.00
Assist attorney in preparing damage model and response to request for
Debra Green 04/28/2020 disclosure. 1.5 $150.00 $225.00
Debra Green 05/01/2020 Assist attorney in preparing and serving response to request for disclosure and $150.00
damage model. 2.0 $300.00
Dax O. Faubus 05/01/2020 Review and finalize Plaintiffs' response to Defendant’s request for disclosure. 0.9 $450.00 $405.00
Debra Green 05/08/2020 Assist attorney in updating damage model. 0.5 $150.00 $75.00
Begin preparing shells for discovery responses; begin drafting responses to $100.00
Jamie A. Diaz 06/03/2020 discovery. 2.0 $200.00
Continue drafting responses to Greeneco's RFP and Interrogatories; review case $100.00
Jamie A. Diaz 06/04/2020 documents; email correspondence with client concerning same. 2.0 $200.00
Continue drafting responses to Greeneco's RFP and Interrogatories; sent to DG; $100.00
continue to review case documents; email correspondence with client
Jamie A. Diaz 06/05/2020 concerning same; receipt and review client documents. 3.5 $350.00
Assist attorney in preparing response to Greeneco’s interrogatories and request $150.00
Debra Green 06/05/2020 for production; review case documents and prepared document production. 2.0 $300.00
Review and finalize the Pltffs responses to Def's RFP and Interrogatories per $100.00
Jamie A. Diaz 06/08/2020 DOF instructions; review and prepare client documents for production. 1.5 $150.00
Review and finalize Plaintiffs' response to interrogatories and request for $450.00
Dax O. Faubus 06/08/2020 production. 1.8 $810.00
Email with opposing counsel requesting extension of time to respond to $100.00
Jamie A. Diaz 06/08/2020 purchase offer. 0.5 $50.00
Receipt and respond to email from opposing counsel concerning purchase offer $450.00
Dax O. Faubus 06/08/2020 and extension of time to respond. 0.3 $135.00
Receipt and review email from opposing counsel concerning election to $450.00
Dax O. Faubus 06/15/2020 exercise buy-back option. 1.5 $675.00
Dax O. Faubus 06/20/2020 Telephone conference with clients concerning purchase offer. 1.5 $450.00 $675.00
Debra Green 06/20/2020 Status conference with attorney concerning damage model and purchase offer. 0.5 $150.00 $75.00
Dax O. Faubus 06/22/2020 Prepare response to purchase offer. 2.5 $450.00 $1,125.00
Debra Green 06/22/2020 Assist attorney in preparing response to purchase offer. 1.0 $150.00 $150.00
TOTAL: $32,358.83

Case Info

Judge

Ellisor, John Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

July 15, 2020

Case Filing Date

March 01, 2019

County

Parties

Blue Marlin Resources, L.L.C. Counter Plaintiff/petitioner
Blue Marlin Resources, L.L.C. Defendant
Cohn, H.miles Attorneys for Defendants
Cohn, H.miles Attorney for the Defendant
Dax O. Faubus Attorneys for Plaintiffs
Dax O. Faubus Attorney for the Plaintiff
Faubus, Dax O. Attorneys for Plaintiffs
Faubus, Dax O. Attorney for the Plaintiff
GreenEco Builders, L.L.C. Counter Plaintiff/petitioner
GreenEco Builders, L.L.C. Defendant
Melinda M. Riseden Attorneys for Defendants
Melinda M. Riseden Attorney for the Defendant
Welch, Jennifer Counter Defendant/respondent
Welch, Jennifer Plaintiff
Welch, Robert Counter Defendant/respondent
Welch, Robert Plaintiff
Douglas Appling Attorneys for Defendants
Joe Savoie Attorney

For full print and download access, please subscribe at https://www.trellis.law/.

Motion-Secondary: Robert and Jennifer Welch vs. GreenEco Builders, L.L.C.

Preview

Related Topics

Case Info

Parties