Motion to Abate in Randy Sanchez, Et Al vs. GreenEco Builders, L.L.C.| Trellis.Law

On March 01, 2019 a Motion-Secondary was filed involving a dispute between Sanchez, Christine, Sanchez, Randy, and Greeneco Builders, L.L.C., for Contract - Debt - Commercial/Consumer in the District Court of Galveston County.

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Filed: 7/21/2020 4:37 PM
JOHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 44712834
By: Shailja Dixit
7/21/2020 4:42 PM
CAUSE NO. 19-CV-0342

RANDY SANCHEZ and § IN THE DISTRICT COURT OF
CHRISTINE SANCHEZ §
Plaintiffs, §
§ GALVESTON COUNTY, TEXAS
vs. §
§
GREENECO BUILDERS, L.L.C. § 10TH 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

COME NOW, Randy Sanchez and Christine Sanchez (“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. Defendant’s motion should be

denied.
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 two

weeks 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 and

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
designated experts. 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 21st 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
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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-0342; Randy Sanchez and Christine Sanchez v. Greeneco
th
Builders, L.L.C.; In the 10 Judicial District Court of Galveston County, Texas;

Dear Mr. Cohn:

I write in response to your client’s election to purchase my clients’ home pursuant
to the contract and §27.0042 of the Residential Construction Liability Act.

Your client’s demand is unreasonable and obtuse, to say the least. It demands that
my clients turnover their home for less than market value, vacate their home within 90
days, with insufficient compensation for the cost to move from the home; all the while
providing practically no compensation for the expenses and fees incurred in prosecuting
this matter against your client. If the Sanchezs were to comply with this demand, they
would not be compensated enough to even pay off their mortgage, much less make a down
payment on a new home.

Such a demand is inherently unreasonable.

Your letter seems to suggest that absent information from my office, your client
cannot make a reasonable offer to compensate my clients to move out of the home or to
pay their expert and attorney’s fees. Is your client unable to perform any research to
determine the cost to move from such a house? Has your client not read the invoices from
our engineers and consultants in this case? Is your client unable to determine what a
reasonable attorney fee would be in light of all the work it has required by my office with
its spurious filings? How much has your client paid your firm, Mr. Cohn, only
$10,000.00? §27.0042 obligates your client, not mine, to determine the reasonable terms
under which it may invoke the extraordinary right to demand my clients to sell their home.
Your client has not met that obligation.
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-

As such, my clients are fully within their rights to reject Greeneco’s demand and
continue litigating this matter. I have been authorized, however, to counter your client’s
demand with the following terms. Your client is statutorily and contractually entitled to
purchase the home for what the Sanchezs paid for it over 2 ½ years ago. Accordingly, the
purchase price and closing costs set out in your May 29, 2020 letter appear correct. If your
client wishes to settle this matter on the basis of forcing my clients to sell their home, then
it must come to terms with the fact that reasonable compensation must be paid on the
remaining elements of §27.0042.

We have provided you information establishing the improvements to the home,
which your client will pay for. (See bates labeled documents SANCHEZ 000561-000564).
Your client will pay a reasonable cost to move from the residence. This will include the
cost to store contents for up to six months while my clients find 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 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’ First Amended 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: $227,560.00
Closing Costs: $7,484.74
Home Improvements: $300.00
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-

Moving Costs: $32,996.46
Attorney’s Fees $35,964.42
Expert Fees: $9,820.83
Total: $314,126.45

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.

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

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
Purchase Counteroffer

Purchase Price $227,560.00 Home
Improvements

Closing Costs $7,484.74 Garage Door $300.00
Opener & Install

Home $300.00 Total Home $300.00
Improvements Improvements

Moving Costs $32,996.46

Attorney’s Fees $35,964.42

Expert Fees $9,820.83 Moving Costs

Move Out $2,940.00

Storage $1,272.00

Total: $314,126.45 Contents Cleaning $21,843.46
(Per Riverstone
Building &
Consulting Mold
Remediation
Report)

Contents $6,941.00
Replacement

Total Moving $32,996.46
Costs

1
Attorney’s Fees
Employee Activity Date
Memo/Description Duration Rate Amount
Initial teleconference with clients; receipt and review client materials and
Dax O. Faubus
11/02/2018 1.1 $450.00
mold report from AQ Testing. $495.00
Status conference concerning new client; prepare and forward fee
Debra Green
11/06/2018 1.0 $150.00
agreement. $150.00
Receipt and review signed fee agreement; open new case; email with clients
Debra Green
11/07/2018 0.8 $150.00
concerning documents; conference with expert concerning inspection. $112.50
Debra Green
11/12/2018Email with clients concerning case documents. 0.6 $150.00 $90.00
Debra Green
11/14/2018Assist attorney in preparing and serving RCLA notice letter.
1.0 $150.00 $150.00
Dax O. Faubus
11/14/2018Draft and revise RCLA notice. 1.5 $450.00 $675.00
Receipt and review proposal from DD Mechanical; forward same to client;
Debra Green
11/22/2018 1.0 $150.00
prepare for production. $150.00
Dax O. Faubus
11/22/2018Receipt and review proposal from DD Mechanical. 0.8 $450.00 $360.00
Dax O. Faubus
11/29/2018Receipt and review RCLA correspondence from opposing counsel.
0.5 $450.00 $225.00
Receipt and review email from opposing counsel concerning inspection;
Debra Green
11/30/2018 0.1 $150.00
forward same to client. $15.00
Dax O. Faubus
11/30/2018Receipt and review email correspondence re: RCLA inspections.
0.4 $450.00 $180.00
Conference with experts concerning inspection; Email with client
Debra Green
12/07/2018 0.1 $150.00
concerning same. $15.00
Angela Petro
12/12/2018Travel to and attend Inspection. 3.0 $100.00 $300.00
Angela Petro
12/13/2018Travel to and attend inspection. 5.0 $100.00 $500.00
Debra Green
12/17/2018Email with clients concerning recent inspection. 0.6 $150.00 $90.00
Receipt and review correspondence from opposing counsel; forward same
Debra Green
12/28/2018 0.6 $150.00
to clients. $90.00
Dax O. Faubus
12/28/2018Receipt and review RCLA offer from opposing counsel.
1.5 $450.00 $675.00
Status conference concerning deadline to respond to RCLA offer; email
Debra Green
01/22/2019 0.5 $150.00
with opposing counsel requesting extension to respond. $75.00
Dax O. Faubus
01/24/2019Draft and revise RCLA correspondence to opposing counsel.
1.8 $450.00 $810.00
Angela Petro
02/26/2019Assisted attorney with finalizing petitions. 1.0 $100.00 $100.00
Prepared and Drafted Clients Original Petition and RFD, Case Information
Terri Webb02/27/2019 1.3 $85.00
Sheet, and Request for Service. $110.50
Debra Green
03/01/2019Assist attorney in preparing and filing original petition.
1.0 $150.00 $150.00
Dax O. Faubus
03/01/2019Draft and revise original petition and request for disclosures.
3.4 $450.00 $1,530.00
Dax O. Faubus
03/04/2019Receipt and review Court’s notice of case setting.0.3 $450.00 $135.00
Debra Green
03/07/2019Email with client concerning case status and inspection.
0.2 $150.00 $30.00
Ada I. Ferrer
03/12/2019Review and analyze case file. 0.3 $250.00 $62.50
Email with process server concerning status of service; calendar deadline
Debra Green
03/18/2019 0.2 $150.00
for Defendant to file answer. $30.00
Review the return from the process server. Calculate the answer date.
Ada I. Ferrer
03/25/2019 0.2 $250.00
Review Omnifocus to verify the date was entered. $41.67
Debra Green
03/26/2019Conference with mold expert concerning inspection.0.6 $150.00 $90.00
Receipt and review correspondence from opposing counsel; forward same
Debra Green
04/05/2019 0.1 $150.00
to clients. $15.00
Receipt and review correspondence from opposing counsel re: remedial
Dax O. Faubus
04/05/2019 0.3 $450.00
work. $135.00
Receipt and review Defendant’s answer and plea in abatement; forward
Debra Green
04/08/2019 0.2 $150.00
same to clients. $30.00
Receipt and review defendants Plea in Abatement, original answer and
Dax O. Faubus
04/08/2019 1.6 $450.00
general denial $720.00
Review the returned affidavit from the client. Prepare the response to the
Ada I. Ferrer
04/17/2019 0.5 $250.00
plea in abatement. $125.00
Draft discovery requests. Draft affidavit and response to plea in
Ada I. Ferrer
04/17/2019 1.0 $250.00
abatement. $250.00
Dax O. Faubus
04/17/2019Draft and revise first written discovery requests.2.6 $450.00 $1,170.00
Assist attorney in preparing and filing response to motion to abate and
Debra Green
04/18/2019 1.0 $150.00
controverting affidavit. $150.00
Debbie Review and revisions to1st Integrated Discovery Requests to Defendant,
04/19/2019 0.8 $150.00
Pellegrin service of same on opposing counsel. $120.00
Draft and revise Plaintiffs amended response to defendants plea in
Dax O. Faubus
04/22/2019 1.5 $450.00
abatement. $675.00
Receipt and review defendants objection and responses to plaintiffs first
Dax O. Faubus
05/17/2019 2.1 $450.00
written discovery requests. $945.00
Ada I. Ferrer
05/22/2019Review FHA information. 0.3 $250.00 $62.50
Review of discovery responses; conference with D. Faubus, D. Green and
Debbie
05/22/2019A. Ferrer concerning same; preparation and transmittal of correspondence
0.8 $150.00
Pellegrin
to opposing counsel concerning discovery responses. $120.00
Draft and review correspondence to opposing counsel re: discovery
Dax O. Faubus
05/22/2019 0.3 $450.00
responses. $135.00
Conduct research regarding FHA loans. Review the docket control order
Ada I. Ferrer
05/23/2019 0.6 $250.00
and instruct D. Green to contact client. $145.83
Conferences with D. Faubus, D. Green and A. Ferrer re: status conference
Debbie of this date; telephone conferences with opposing counsel concerning
05/23/2019 1.0 $150.00
Pellegrin status conference of this date; telephone conferences with Court
Coordinator concerning status conference of this Date. $150.00
Prepare for and attend status conference; eceipt and review signed docket
Dax O. Faubus
05/23/2019 2.0 $450.00
control order. $900.00
Debra Green
05/24/2019Received and docketed docket control order. 0.7 $150.00 $105.00
Debbie
05/24/2019Transmittal of DCO to client and request for additional documents.
0.8 $150.00
Pellegrin $120.00
Dax O. Faubus
05/24/2019Receipt and review defendants request for oral hearing.
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 0.8 $250.00
limitations. $187.50
Assist attorney in preparing for hearing; status conference concerning
Debra Green
07/29/2019 0.5 $150.00
outcome of hearing. $75.00
Prepare for and attend oral hearing on Defendants Plea in Abatement;
Dax O. Faubus
07/29/2019 2.5 $450.00
receipt and review signed agreed order of abatement. $1,125.00
Dax O. Faubus
07/30/2019Receipt and review Court's notice of order entry. 0.4 $450.00 $180.00
Erika Fernandez
10/09/2019Assisted attorney in bate labeling client documents.
1.2 $85.00 $97.75
Erika Fernandez
10/23/2019Assisted attorney in bates labeling client documents.
0.2 $85.00 $12.75
Erika Fernandez
10/23/2019Assisted attorney in bates labeling client documents.
0.3 $85.00 $21.25
Erika Fernandez
10/23/2019Assisted attorney in bates labeling client documents.
0.5 $85.00 $39.67

1
Employee Activity Date
Memo/Description Duration Rate Amount
Receipt and review mold protocol from Linda Lauver; forward same to
Debra Green
10/31/2019 1.0 $150.00
clients; prepare and produce supplemental document production. $150.00
Dax O. Faubus
10/31/2019Receipt and review mold protocol from AQ Testing. 2.4 $450.00 $1,080.00
Debra Green
11/13/2019Status conference concerning status of abatement and next steps.
0.2 $150.00 $30.00
Assist attorney in preparing and filing motion to lift abatement and for new
Debra Green
11/19/2019 1.0 $150.00
scheduling order. $150.00
Draft and revise Plaintiffs Motion to Lift Abatement and Request fro New
Dax O. Faubus
11/19/2019 1.5 $450.00
Docket Control Order and Request for Oral Hearing. $675.00
Dax O. Faubus
11/20/2019Receipt and review Court’s notice of case setting.0.4 $450.00 $180.00
Receipt and review correspondence from opposing counsel re: construction
Dax O. Faubus
11/21/2019 0.5 $450.00
defects. $225.00
Draft and revise correspondence to opposing counsel re: Discovery
Dax O. Faubus
11/22/2019 0.5 $450.00
requests. $225.00
Receipt and review correspondence from opposing counsel re: construction
Dax O. Faubus
11/27/2019 0.5 $450.00
defects. $225.00
Receipt and review report from Apollo BBC; forward same to client;
Debra Green
11/28/2019 1.0 $150.00
prepare for production. $150.00
Dax O. Faubus
11/28/2019Receipt and review report from expert Apollo BBC. 2.5 $450.00 $1,125.00
Dax O. Faubus
12/03/2019Draft and revise correspondence to opposing counsel.
0.3 $450.00 $135.00
Confer with DG re: hearing on Motion to Lift Abatement. Draft a Notice of
Jamie A. Diaz
12/10/2019 0.5 $100.00
Hearing and filed with the court and served on all parties. $50.00
Receipt and review Court's notice of oral hearing on Plaintffs Motion to
Dax O. Faubus
12/10/2019 0.3 $450.00
Lift Abatement and Request for New Docket Control order. $135.00
Debra Green
12/12/2019Assist attorney in preparing for hearing. 0.5 $150.00 $75.00
Receipt and review Defendants response to Plaintiffs Motion to Lift
Dax O. Faubus
12/12/2019 0.8 $450.00
Abatement. $360.00
Jamie A. Diaz
12/13/2019Calendar and save in Omni the New DCO. 1.0 $100.00 $100.00
Prepare for and attend oral hearing on Plaintiffs Motion to Lift Abatement;
Dax O. Faubus
12/13/2019 3.5 $450.00
receipt and review signed docket control order. $1,575.00
Dax O. Faubus
12/16/2019Receipt and review Court's notice of order entry. 0.3 $450.00 $135.00
Jamie A. Diaz
12/20/2019Sent a Trial reminder to the Experts and the clients.
0.3 $100.00 $25.00
Receipt and review defendants first amended objection and responses to
Dax O. Faubus
01/06/2020plaintiffs first written discovery requests; receipt and review defendants
1.2 $450.00
responses to request for disclosure. $540.00
Receipt and review defendants first request for production and
Dax O. Faubus
03/18/2020 1.4 $450.00
interrogatories to plaintiffs. $630.00
Erika
03/30/2020Work on Responses to Greeneco's First RFPs and ROGs.
1.0 $100.00
Stubblefield $100.00
Dax O. Faubus
04/01/2020Receipt and review defendants first request for disclosures.
0.3 $450.00 $135.00
Receipt and review Request for Disclosure from opposing counsel;
Jamie A. Diaz
04/02/2020 0.3 $100.00
forward same to client. $25.00
Receipt and review email from opposing c

Case Info

Judge

Neves, Kerry Track Judge’s New Case

Case No.

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Document Filed Date

July 21, 2020

Case Filing Date

March 01, 2019

County

Parties

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
H.miles Cohn Attorneys for Defendants
H.miles Cohn Attorney for the Defendant
Sanchez, Christine Counter Defendant/respondent
Sanchez, Christine Plaintiff
Sanchez, Randy Counter Defendant/respondent
Sanchez, Randy Plaintiff
Melinda Riseden Attorneys for Defendants

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Motion-Secondary: Randy Sanchez, Et Al vs. GreenEco Builders, L.L.C.

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