ATI Jet Sales, LLC v. City of El Paso, Texas and Maria O. Pasillas, Tax Assessor - Collector, City of El Paso

ACCEPTED
08-21-00208-CV
08-21-00208-CV EIGHTH COURT OF APPEALS
EL PASO, TEXAS
1/23/2023 9:47 PM
ELIZABETH G. FLORES
CLERK
No. 08-21-00208-CV
FILED IN
8th COURT OF APPEALS
IN THE COURT OF APPEALS FOR THE EIGHTH DISTRICT
EL PASO, TEXAS
EL PASO, TEXAS 1/23/2023 9:47:52 PM
ELIZABETH G. FLORES
Clerk
ATI JET SALES, LLC
Appellant,
v.
CITY OF EL PASO, TEXAS AND MARIA O. PASILLAS, TAX ASSESSOR-
COLLECTOR, CITY OF EL PASO
Appellees.
Appeal from the County Court at Law No. 6 of El Paso County, Texas
Cause No. 2021DCV1168
The Honorable M. Sue Kurita Presiding
REPLY BRIEF OF APPELLANT ATI JET SALES, LLC
Kory Ryan
Texas Bar No. 24068065
Brittany E. Dumas
Texas Bar No. 24101713
RYAN LAW FIRM, PLLC
13155 Noel Road, Suite 1850
Dallas, Texas 75240
Tel: (972) 250-6363
Fax: (972) 250-3599
Counsel for ATI Jet Sales, LLC
ORAL ARGUMENT REQUESTED. September 6, 2022
TABLE OF CONTENTS
TABLE OF CONTENTS .......................................................................................... ii
INDEX OF AUTHORITIES.................................................................................... iii
APPELLANT’S REPLY BRIEF ...............................................................................1
I. GOVERNMENTAL IMMUNITY DOES NOT SHIELD THE
TAXING AUTHORITIES IN THIS CASE AS JET SALES
PLED A VIABLE TAKINGS CLAIM. ................................................1
A. Texas law requires that the jurisdictional issue be resolved
liberally in favor of the plaintiff without a review on the
merits of the cause of action. ......................................................2
B. Jet Sales affirmatively demonstrated a viable takings
claim; thus, dismissal was in error. .............................................3
C. The Taxing Authorities’ seizure of the aircraft was not
lawful as they improperly used their taxing power. ...................5
D. Jet Sales properly demonstrated that the seizure was for
public use. ...................................................................................7
E. Jet Sales had no adequate remedies in which to recover the
aircraft. ........................................................................................8
II. GOVERNMENTAL IMMUNITY DOES NOT SHIELD THE
TAXING AUTHORITIES IN THIS CASE FROM ANY
ULTRA VIRES ACTS. .......................................................................11
A. The Taxing Authorities’ argument that the declaratory
judgment action is moot was not properly raised at the trial
court. In addition, Exhibit A to the Taxing Authorities’
Response Brief is evidence not contained within the record
and should not be admitted into this proceeding. .....................11
CONCLUSION AND PRAYER .............................................................................13
CERTIFICATE OF COMPLIANCE .......................................................................14
CERTIFICATE OF SERVICE ................................................................................15
ii
INDEX OF AUTHORITIES
Cases
Bland Indep. Sch. Dist. v. Blue, 34 S.W.3d 547 (Tex. 2000) ....................................3
Castleberry v. Goolsby Bldg. Corp., 617 S.W.2d 665 (Tex. 1981)...........................3
City of Dallas v. Heard, 252 S.W.3d 98 (Tex. App.—Dallas 2008, pet.
denied) ........................................................................................................... 11, 12
City of Dallas v. Jennings, 142 S.W.3d 310 (Tex. 2004) ..........................................8
City of Dallas v. VSC, LLC, 347 S.W.3d 231 (Tex. 2011) ........................................9
City of Keller v. Hall, 433 S.W.3d 708 (Tex. App.—Fort Worth 2014, pet.
denied) ........................................................................................................... 2, 4, 5
City of Robinson v. Leuscher, 636 S.W.3d 48 (Tex. App.—Waco 2021, pet.
filed) .......................................................................................................................8
City of San Antonio v. Pollock, 284 S.W.3d 809 (Tex. 2009) ...................................8
City of Webster v. Hunnicutt, 650 S.W.3d 792 (Tex. App.—Houston [14th
Dist.] 2022, no pet. h.) .................................................................................. 2, 3, 5
County of Burleson v. General Electric Capital Corp., 831 S.W.2d 54 (Tex.
App.—Houston [14th Dist.] 1992, writ denied) ................................................6, 7
Harris County v. Luna-Prudencio, 294 S.W.3d 690 (Tex. App.—Houston
[1st Dist.] 2009, no pet.) .........................................................................................3
Harris Cty Flood Control Dist. v. Kerr, 499 S.W.3d 793 (Tex. 2016) .....................1
Paramount Pipe & Supply Co., Inc. v. Muhr, 749 S.W.2d 491 (Tex. 1988).............3
Rylander v. Palais Royal, Inc., 81 S.W.3d 909 (Tex. App.—Austin 2002,
pet. denied))............................................................................................................6
Sci. Spectrum, Inc. v. Martinez, 941 S.W.2d 910 (Tex. 1997) ..................................2
State v. Brownlow, 319 S.W.3d 649 (Tex. 2010) ......................................................1
Tex. Dep't of Transp. v. A.P.I. Pipe &
Supply, LLC, 397 S.W.3d 162 (Tex. 2013)........................................................2, 4
iii
Texas Dep't of Parks & Wildlife v. Miranda, 133 S.W.3d 217 (Tex. 2004) .............3
Texas Workforce Corp’n v. Midfirst Bank, 40 S.W.3d 690 (Tex. App.—
Austin 2001, pet. denied) .......................................................................................6
Villareal v. Harris Co., 226 S.W.3d 537 (Tex. App.—Houston [1st Dist.]
2006, no pet.)..........................................................................................................6
Other Authorities
TEX. TAX CODE § 33.24 .......................................................................................9, 10
TEX. TAX CODE § 41.411 .........................................................................................10
TEX. TAX CODE § 41.4115 ...................................................................................10
TEX. TAX CODE § 41.44 .......................................................................................10
Rules
TEX. R. CIV. P. 45 .......................................................................................................8
TEX. R. CIV. P. 47 .......................................................................................................8
iv
APPELLANT’S REPLY BRIEF
In response to the Taxing Authorities’ arguments relating to Jet Sales’ takings
cause of action and declaratory judgment action presented in their appellate brief,
Jet Sales will address each argument in turn. For the reasons explained below, Jet
Sales respectfully requests that the Court reverse the trial court’s judgment, and
remand to the trial court for adjudication on Jet Sales’ claims on the merits.
I. GOVERNMENTAL IMMUNITY DOES NOT SHIELD THE TAXING
AUTHORITIES IN THIS CASE AS JET SALES PLED A VIABLE
TAKINGS CLAIM.
Governmental immunity, in this case, does not shield the Taxing Authorities
for their actions made in contravention of the Takings Clause. Texas case law is
clear that “[s]overeign and governmental immunity do not shield the government
from liability for compensation under the takings clause. Harris Cty Flood Control
Dist. v. Kerr, 499 S.W.3d 793, 99 (Tex. 2016); State v. Brownlow, 319 S.W.3d 649,
52 (Tex. 2010). As stated in Jet Sales’ Appellate Brief, immunity does not bestow
carte blanch, blanket authority to a governmental agency or employee. See APT
Brief at 41. Although the Taxing Authorities were permitted to raise immunity as a
defense via a plea to the jurisdiction, that does not guarantee that immunity be found
in all instances. Rather, to defeat an immunity claim for purposes of jurisdiction, a
plaintiff must demonstrate that there is viable takings claim. See Tex. Dep't of
1
Transp. v. A.P.I. Pipe & Supply, LLC, 397 S.W.3d 162, 66 (Tex. 2013) (emphasis
added).
When determining whether a claim of immunity successfully defeats
jurisdiction, the court should determine whether a viable takings claim exists, not
whether the Plaintiff established by a preponderance of the evidence that a takings
did in fact occurred. See, e.g., City of Keller v. Hall, 433 S.W.3d 708, 728 (Tex.
App.—Fort Worth 2014, pet. denied). Only in those instances where it is undisputed
that there is not a viable takings claim should the plea be granted. See City of
Webster v. Hunnicutt, 650 S.W.3d 792, 797-98 (Tex. App.—Houston [14th Dist.]
2022, no pet. h.). If the governmental defendant produces evidence to demonstrate
as a matter of law that there is not a viable claim, then the court should grant the plea
to the jurisdiction. Ibid.; see also A.P.I. Pipe, 397 S.W.3d at 166.
A. Texas law requires that the jurisdictional issue be resolved liberally
in favor of the plaintiff without a review on the merits of the cause
of action.
Texas case law makes clear that when determining a jurisdictional issue, the
court should take as true all evidence favorable to the plaintiff and “indulg[e] every
reasonable inference and resolv[e] any doubts in [the plaintiff’s] favor” for purposes
of the jurisdictional question. Sci. Spectrum, Inc. v. Martinez, 941 S.W.2d 910, 911
(Tex. 1997). That is, the court should resolve the issue liberally in favor of conferring
2
jurisdiction. Harris County v. Luna-Prudencio, 294 S.W.3d 690, 696 (Tex. App.—
Houston [1st Dist.] 2009, no pet.).
Not only should the pleading be read favorably in favor of Plaintiff, but Texas
Rules of Civil Procedure 45 and 47 require that the original pleading give a short
statement of the cause of action sufficient to give the opposing party fair notice of
the claim involved. TEX. R. CIV. P. 45, 47; Paramount Pipe & Supply Co., Inc. v.
Muhr, 749 S.W.2d 491, 494 (Tex. 1988); Castleberry v. Goolsby Bldg. Corp., 617
S.W.2d 665, 666 (Tex. 1981). Rule 45 does not require that the plaintiff lay out its
evidence that it will rely upon to establish the asserted cause of action. Muhr, 749
S.W.2d at 494-95. Texas Dep't of Parks & Wildlife v. Miranda, 133 S.W.3d 217,
230 (Tex. 2004). When considering the jurisdictional question, a court should only
consider the pleadings and evidence pertinent to make a determination on the
jurisdictional inquiry and not the merits of the cause of action. See City of Webster v.
Hunnicutt, 650 S.W.3d 792, 797-98 (Tex. App.—Houston [14th Dist.] 2022, no pet.
h.) (citing Bland Indep. Sch. Dist. v. Blue, 34 S.W.3d 547, 555 (Tex. 2000)).
B. Jet Sales affirmatively demonstrated a viable takings claim; thus,
dismissal was in error.
As stated in Jet Sales’ Appellate Brief, Jet Sales pled each element necessary
to demonstrate that a takings occurred in this instance. See APT Brief at 43-44. The
Taxing Authorities allege that (1) there was not a taking as the seizure was lawful;
(2) the seizure was not for “public use”; and (3) that Jet Sales failed to avail itself of
3
remedies to recover the aircraft. See AEE Brief at 16-30. As further demonstrated
below, the Taxing Authorities cannot show as a matter of law that Jet Sales had no
viable takings claim.
In response to Jet Sales’ argument that it did in fact allege a viable takings
claim, the Taxing Authorities misconstrue what is required for jurisdictional
purposes. Whether or not Jet Sales would succeed on its takings argument is a
question for the trier of fact See City of Keller v. Hall, 433 S.W.3d 708, 728 (Tex.
App.—Fort Worth 2014, pet. denied). What is required at this jurisdiction juncture,
is merely that Jet Sales demonstrated that there was a viable takings claim as
discussed supra. See ibid.
Various Texas courts have examined takings claim cases wherein a defendant
alleged that governmental immunity precluded jurisdiction. See, e.g., Texas Dept. of
Transp. v. A.P.I. Pipe & Sup., LLC, 397 S.W.3d 162, 166 (Tex. 2013). For instance,
in A.P.I. Pipe, the Supreme Court of Texas found that a takings claim was not viable
and therefore the Court found that the trial court lacked jurisdiction. Ibid. In that
case, however, the Court found that the Plaintiff did not demonstrate an ownership
interest in the property taken. Ibid. As ownership of the property taken is a
fundamental tenant for a takings claim to exist, the Court found that there could not
be a viable takings claim. Ibid.4
In Hunnicutt, the Fort Worth Court of Appeals found that the plaintiff did not
plead a viable takings claim as well. See City of Webster v. Hunnicutt, 650 S.W.3d
792, 797-98 (Tex. App.—Houston [14th Dist.] 2022, no pet. h.). In that case, the
plaintiff pled a tort claim against the City. Ibid. at 798-800. As a takings claim must
be based on intentional actions by the City, the Court found that there was not a
viable takings claim. Ibid.
In contrast, courts have found that if there is a fact issue surrounding one of
the elements of the takings claim, that dismissal of the case on jurisdictional grounds
is inappropriate. See City of Keller v. Hall, 433 S.W.3d 708, 728 (Tex. App.—Fort
Worth 2014, pet. denied). In Hall, the Fort Worth Court of Appeals affirmed the trial
court’s decision wherein it denied the city’s plea to the jurisdiction. Ibid. In that case,
the City argued that there was no subject matter jurisdiction for an inverse
condemnation claim as the evidence admitted showed that the City did not know that
the actions it took would result in damage to the property—i.e., that the act was not
intentional (a requirement of the claim). See ibid. at 717. The court ultimately found
that there was a factual question concerning the City’s knowledge about whether
damage would result, which precluded the plea to the jurisdiction. Ibid. at 728.
C. The Taxing Authorities’ seizure of the aircraft was not lawful as
they improperly used their taxing power.
The Taxing Authorities allege that because the seizure of the aircraft was
lawful, there can be no taking. See AEE Brief at 16. In support for this position, the
5
Taxing Authorities cite to Villareal for the proposition that when a governmental
agency uses its taxing power to take property to collect taxes, that seizure “does not
amount to a ‘taking’ as contemplated by Article I, Section 17 of the Texas
Constitution.” See AEE Brief at 20 (citing to Villareal v. Harris Co., 226 S.W.3d
537, 544 (Tex. App.—Houston [1st Dist.] 2006, no pet.); Rylander v. Palais Royal,
Inc., 81 S.W.3d 909, 915 (Tex. App.—Austin 2002, pet. denied)).
The Taxing Authorities’ argument, however, fails as they misconstrue
Villareal. As Villareal and other Texas cases make clear, a governmental agency
using its taxing power to seize property may not be considered a taking.
See Rylander v. Palais Royal, Inc., 81 S.W.3d 909, 915 (Tex. App.—Austin 2002,
pet. denied) (emphasis added). But, as in this case, if the government improperly
uses its taxing power to take property for public use, a taking can occur. See, e.g.,
Villarreal v. Harris Cnty., 226 S.W.3d 537, 544 (Tex. App.—2006) (emphasis
added). Various Texas courts have recognized that takings action could be
warranted when a taxing authority improperly uses its taxing powers. See, e.g., Texas
Workforce Corp’n v. Midfirst Bank, 40 S.W.3d 690, 697 (Tex. App.—Austin 2001,
pet. denied); County of Burleson v. General Electric Capital Corp., 831 S.W.2d 54(Tex. App.—Houston [14th Dist.] 1992, writ denied). The reason for this distinction
is that an improper use of its taxing power is not actually a use of taxing power at
all, but rather a taking. See Midfirst Bank, 40 S.W.3d at 697.
6
In General Electric, the court recognized a takings action when a taxing
authority illegally sold a mobile home in which a company had a security
interest. See Burleson v. Gen. Elec. Capital Corp., 831 S.W.2d 54, 57 (Tex. App.—
Houston [14th Dist.] 1992, writ denied). In that case, a local taxing authority
foreclosed on a debtor's mobile home to collect the deficient tax owed on the
property. Ibid. at 57-58. In foreclosing on the mobile home, the taxing authority
“acted contrary to the required procedures” for the foreclosure of the lien when it
failed to provide notice to the holder of a perfected security interest. Ibid. The court
expressly rejected the taxing authority’s claim that this could not amount to a taking
and held that the taxing authority's “actions have damaged [the company] and
deprived it of a valuable property interest without due process or
compensation.” Ibid. at 59.
In this case, the Taxing Authorities seized property of one taxpayer—Jet Sales
(Appellant, here) in satisfaction of delinquent taxes owed by another taxpayer—
Sales West. The delinquent tax statement listed Sales West as the owner. See 3RR
185-86. Seizing property of one taxpayer to satisfy another’s debt is an improper use
of taxing powers.
D. Jet Sales properly demonstrated that the seizure was for public use.
The Taxing Authorities’ seizure of the aircraft was for public use. The Taxing
Authorities seized the aircraft in satisfaction of delinquent property taxes of another
7
taxpayer in the county. In determining whether an act is for public use, Texas case
law indicates that a governmental action that is accidental or negligent does not
confer a benefit to the public. City of Robinson v. Leuscher, 636 S.W.3d 48, 57-58
(Tex. App.—Waco 2021, pet. filed) (citing City of San Antonio v. Pollock, 284
S.W.3d 809, 820 (Tex. 2009)). There must be a showing that the act was intentional.
Ibid. “When damage is merely the accidental result of the government's act, there is
no public benefit and the property cannot be said to be taken or damaged
for public use.” City of Dallas v. Jennings, 142 S.W.3d 310, 313 (Tex. 2004)
(internal quotations and emphasis omitted).
In this case, the Taxing Authorities’ actions were intentional as demonstrated
by the tax warrant and physical seizure of the property. The Taxing Authorities
intended to seize the property for payment of taxes, which undoubtedly benefit the
public. It is undisputed that property taxes fund many public benefits including
funding schools, roadways, and construction among other things. As such, Jet Sales
pled a viable takings claim and should not have been dismissed on jurisdictional
grounds.
E. Jet Sales had no adequate remedies in which to recover the aircraft.
The Taxing Authorities allege that Jet Sales failed to avail itself of remedies
to recover the aircraft and thus, there can be no taking. See AEE Brief at 20. This
argument fails for two reasons. First, the remedies “available” to Jet Sales were not
8
adequate. Second, this argument was not presented in the Plea to the Jurisdiction or
the accompanying hearing.
There are instances in which a governmental agency takes property, but
through an adequate process for obtaining compensation and/or return of the
property, there is no governmental taking. City of Dallas v. VSC, LLC, 347 S.W.3d
231, 236 (Tex. 2011). The Taxing Authorities cite to VSC as authority to demonstrate
that Jet Sales should have availed itself of one of three remedies so that the property
would have been returned and thus, no takings would have occurred. See AEE Brief
at 20-26. In VSC, the Plaintiff had an adequate, legal avenue it could have pursued
to regain possession of the vehicles. Ibid. at 249. The Court in VSC found that
“[b]ecause VSC could seek possession or compensation through a remedial statutory
scheme, it could not ignore that scheme in favor of initiating a constitutional takings
suit.” Ibid.
The Taxing Authorities, here, allege that Jet Sales had three avenues in which
to recover the aircraft. See AEE Brief at 20-26. First, Jet Sales could have paid the
taxes due under protest. Ibid. at 23-24. Second, Jet Sales could have delivered a cash
or surety bond to the taxing unit’s tax collector under Section 33.24 of the Texas Tax
Code. Ibid. at 24-25. Third, Jet Sales could have posted a bond of $200,000 with the
trial court until final resolution of the case. Ibid. at 25. Each option, however, is not
an adequate remedy and each fails in turn.
9
Posting a bond and/or paying cash of $200,000 or higher to recover its seized
property is not an adequate remedy for Jet Sales. In addition, option two under
Section 33.24 of the Texas Tax Code, is not applicable here. Pursuant to Section
33.24, “a person may prevent seizure of property or sale of property seized by
delivering to the collector a cash or surety bond conditioned on payment of the tax
before delinquency.” TEX. TAX CODE § 33.24. The alleged delinquent taxes dated
back to 2017 thereby making the delinquency date years prior to the seizure.
Although the Taxing Authorities state that the delinquency date can be pushed back
under Sections 41.411, and 41.4115, and 41.44, none of those sections allow for the
date to actually be pushed in this case. See AEE Brief at 25. The sections require a
payment of the amount of taxes due on the property that is not in dispute before the
delinquency date. See TEX. TAX CODE §§ 41.411, 41.4115, and 41.44. In this case,
no payment had been made prior to the delinquency date as Jet Sales never received
notice of taxes owed. Thus, Jet Sales had no recourse through these provisions of the
Tax Code. Accordingly, requiring a Plaintiff to pay over $200,000 or more to recover
property that was illegally seized cannot be an adequate remedy in which Plaintiff
was required to avail itself.
10
In addition, this issue was not raised in the trial court whereby appellate court
review is appropriate. Appellate court jurisdiction is limited to reviewing a plea to
the jurisdiction as filed and heard and does not extend to grounds outside those
actually raised. See City of Dallas v. Heard, 252 S.W.3d 98, 102 (Tex. App.—
Dallas 2008, pet. denied). Courts of appeals should not consider whether the trial
court erred in denying a plea to the jurisdiction on a ground that was not argued
before the trial court. Ibid. In addition, this argument was not presented as a basis
for the Plea to the Jurisdiction. For both reasons, the Taxing Authorities’ argument
that Jet Sales did not avail itself of remedies and thus cannot claim a takings fails
in its entirety.
II. GOVERNMENTAL IMMUNITY DOES NOT SHEILD THE TAXING
AUTHORITIES IN THIS CASE FROM ANY ULTRA VIRES ACTS.
A. The Taxing Authorities’ argument that the declaratory judgment
action is moot was not properly raised at the trial court. In
addition, Exhibit A to the Taxing Authorities’ Response Brief is
evidence not contained within the record and should not be
admitted into this proceeding.
The Taxing Authorities allege for the first time that the declaratory judgment
action is now moot. See AEE Brief at 25. As an initial matter, this issue was not
brought before the trial court and is wholly outside the record. In addition,
Appellee’s Exhibit A is not included in the record and Jet Sales objects to its
admission in its entirety. This Exhibit has not been authenticated, produced, or
otherwise brought into evidence in any capacity. The purported date on the Exhibit
11
is December 12, 2022, over twelve (12) days after Jet Sales filed its Notice of Appeal
in this case. As such any argument relating to mootness and/or reliance on
Appellee’s Exhibit A is outside the record and was not a consideration when
determining jurisdiction at the trial court level.
Appellate court jurisdiction is limited to reviewing a plea to the jurisdiction
as filed and heard and does not extend to grounds outside those actually raised. See
City of Dallas v. Heard, 252 S.W.3d 98, 102 (Tex. App.—Dallas 2008, pet. denied).
Courts of appeals should not consider whether the trial court erred in denying a plea
to the jurisdiction on a ground that was not argued before the trial court. Ibid.Accordingly any argument as to mootness or Appellee’s Exhibit A is not a
consideration for this Court.
12
CONCLUSION AND PRAYER
For the foregoing reasons, Jet Sales respectfully requests the Court reverse the
trial court’s October 27, 2021 Order granting the Taxing Authorities’ Plea to the
Jurisdiction and Motion to Dismiss and remand to the trial court for adjudication of
Jet Sales’ claims on the merits.
Respectfully submitted,
RYAN LAW FIRM, PLLC
13155 Noel Road, Suite 1850
Dallas, Texas 75240
Ph: 972.250.6363
Fax: 972.250.3599
/s/ Brittany E. Dumas
Brittany E. Dumas
Texas Bar No. 24101713
Brittany.Dumas@ryanlawyers.com
13
CERTIFICATE OF COMPLIANCE
1. This Brief complies with the type-volume limitation Tex. R. App. 9.4(i)
because:
• This brief contains 2,972 words, excluding the parts of the Brief exempted
by Tex. R. App. P. 9.4(i)(1) and (2)(B).
2. This Brief complies with the typeface requirements of Tex. R. App. P. 9.4(e)
and the type style requirements of Tex. R. App. P. 9.4(e) because:
• This Brief has been prepared in a proportionally spaced format using
Microsoft Word in 14 pt. Times New Roman.
/s/ Brittany E. Dumas
Brittany E. Dumas
14
CERTIFICATE OF SERVICE
I certify that a true and correct copy of this motion was filed electronically
and was served on counsel for Appellee on January 23, 2023, pursuant to the Texas
Rules of Appellate Procedure 9.5.
/s/ Brittany E. Dumas
Brittany E. Dumas
15
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Mary Bayer on behalf of Brittany Dumas
Bar No. 24101713
mary.bayer@ryanlawyers.com
Envelope ID: 72066890
Status as of 1/24/2023 1:35 PM MST
Associated Case Party: City of El Paso, Texas
Name BarNumber Email TimestampSubmitted Status
Jose Padilla 24032811 EP.Litigation@lgbs.com 1/23/2023 9:47:52 PM SENT
Associated Case Party: Maria O. Pasillas, Tax Collector-Assessor for the City of El
Paso
Name BarNumber Email TimestampSubmitted Status
Jose Padilla 24032811 EP.Litigation@lgbs.com 1/23/2023 9:47:52 PM SENT
Associated Case Party: ATI Jet Sales, LLC
Name BarNumber Email TimestampSubmitted Status
Brittany Dumas brittany.dumas@ryanlawyers.com 1/23/2023 9:47:52 PM SENT
Dallas OfficeFilings dallasofficefilings@ryanlawyers.com 1/23/2023 9:47:52 PM SENT
Evelin Martinez evelin.martinez@ryanlawyers.com 1/23/2023 9:47:52 PM SENT
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Mary Bayer mary.bayer@ryanlawyers.com 1/23/2023 9:47:52 PM SENT
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