On July 05, 2023 a
Motion-Secondary
was filed
involving a dispute between
James W. Volberding, Receiver,
and
Brown, Kathryn Seewald,
for Other Contract - Under $250,000
in the District Court of Montgomery County.
Preview
Cause No.
JAMES W. VOLBERDING
Plaintiff
IN AND FOR
KATHRYN SEEWALD BROWN
Defendant MONTGOMERY COUNTY, TEXAS
RECEIVER’S REPLY TO FENDANT’S RESPONSE
REGARDING HEARING AND DEPOSITIONS
HE ONORABLE ISTRICT OURT
In her September 27, 2023 response regarding next week aring pertaining
o the motion to disqualify her counsel, Ms. Brown agrees that testimony is required
and that the ctober 11 hearing is the best way to obtain it. Receiver agrees for the
same reason. Depositions are moot.
Respectfully submitted this day of
October
/s/ James W. Volberding
By: ____________________________
JAMES W. VOLBERDING
SBN: 00786313
OLBERDING AW IRM
Plaza Tower
110 North College Avenue
Suite 1850
Tyler, Texas 75702
(903) 5976622 (Office)
(Fax)
email: jamesvolberding@gmail.com
James W. Volberding, Receiver v. Kathryn S. Brown No.
Receiver’s ply to Defendant’s Response Regarding Hearing and Depositions Page
ECEIVER
/s/ Dana E. Lipp
By: ____________________________
DANA E. LIPP
SBN: 24050935
IPP EGAL PLLC
5301 Village Creek Dr., Suite A
Plano, TX 75093
(972) 665 (Office)
(972) 665 0100 (Fax)
Email: dlipp@lipplegal.com
TTORNEY FOR ECEIVER
ERTIFICATE OF ERVICE
Pursuant to Montgomery County Rule of Administration for Civil Cases 9.3,
adopted January 27, 2023, I hereby certify that a true and correct copy of this Receiver’s
Reply to Defendant’s Response Regarding Hearing and Depositions has been delivered this day
of October 2023 (by electronic filing) to:
r. J. Randal Bays
Bays Firm
1503 Hailey Street
Conroe, Texas 77301
(936) 760
Mr. James O. Blackwell, III
3900 Essex Lane, Suite 535
Houston, Texas 77027
(713) 212
jb@blackwelllawfirm.net
r. Dwayne R. Day
3401 Allen Parkway
Suite 101
Houston, Texas 77019
(713) 818
dday@ddaylaw.com
by the following means:
James W. Volberding, Receiver v. Kathryn S. Brown No.
Receiver’s ply to Defendant’s Response Regarding Hearing and Depositions Page
By U.S. Postal Service Certified Mail, R.R.R.
By First Class U.S. Mail
By Special Courier
By Hand Delivery
By Fax before 5 p.m.
By Fax after 5 p.m.
By email to
By email with PDF
By e filing service. /s/ James W. Volberding
JAMES W. VOLBERDING
James W. Volberding, Receiver v. Kathryn S. Brown No.
Receiver’s ply to Defendant’s Response Regarding Hearing and Depositions Page
Document Filed Date
October 03, 2023
Case Filing Date
July 05, 2023
Category
Other Contract - Under $250,000
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Cause No. JAMES W. VOLBERDING Plaintiff IN AND FOR KATHRYN SEEWALD BROWN Defendant MONTGOMERY COUNTY, TEXAS RECEIVER’S REPLY TO FENDANT’S RESPONSE REGARDING HEARING AND DEPOSITIONS HE ONORABLE ISTRICT OURT In her September 27, 2023 response regarding next week aring pertaining o the motion to disqualify her counsel, Ms. Brown agrees that testimony is required and that the ctober 11 hearing is the best way to obtain it. Receiver agrees for the same reason. Depositions are moot. Respectfully submitted this day of October /s/ James W. Volberding By: ____________________________ JAMES W. VOLBERDING SBN: 00786313 OLBERDING AW IRM Plaza Tower 110 North College Avenue Suite 1850 Tyler, Texas 75702 (903) 5976622 (Office) (Fax) email: jamesvolberding@gmail.com James W. Volberding, Receiver v. Kathryn S. Brown No. Receiver’s ply to Defendant’s Response Regarding Hearing and Depositions Page ECEIVER /s/ Dana E. Lipp By: ____________________________ DANA E. LIPP SBN: 24050935 IPP EGAL PLLC 5301 Village Creek Dr., Suite A Plano, TX 75093 (972) 665 (Office) (972) 665 0100 (Fax) Email: dlipp@lipplegal.com TTORNEY FOR ECEIVER ERTIFICATE OF ERVICE Pursuant to Montgomery County Rule of Administration for Civil Cases 9.3, adopted January 27, 2023, I hereby certify that a true and correct copy of this Receiver’s Reply to Defendant’s Response Regarding Hearing and Depositions has been delivered this day of October 2023 (by electronic filing) to: r. J. Randal Bays Bays Firm 1503 Hailey Street Conroe, Texas 77301 (936) 760 Mr. James O. Blackwell, III 3900 Essex Lane, Suite 535 Houston, Texas 77027 (713) 212 jb@blackwelllawfirm.net r. Dwayne R. Day 3401 Allen Parkway Suite 101 Houston, Texas 77019 (713) 818 dday@ddaylaw.com by the following means: James W. Volberding, Receiver v. Kathryn S. Brown No. Receiver’s ply to Defendant’s Response Regarding Hearing and Depositions Page By U.S. Postal Service Certified Mail, R.R.R. By First Class U.S. Mail By Special Courier By Hand Delivery By Fax before 5 p.m. By Fax after 5 p.m. By email to By email with PDF By e filing service. /s/ James W. Volberding JAMES W. VOLBERDING James W. Volberding, Receiver v. Kathryn S. Brown No. Receiver’s ply to Defendant’s Response Regarding Hearing and Depositions Page