ACCEPTED 15-25-00014-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 5/29/2025 7:05 PM No. 15-25-00014-CV CHRISTOPHER A. PRINE CLERK In the Court of Appeals FILED IN 15th COURT OF APPEALS for the Fifteenth District of Texas AUSTIN, TEXAS 5/29/2025 7:05:49 PM CHRISTOPHER A. PRINE Clerk Blackstone Holdings III LP, et al., Appellants, v.
Primexx Energy Opportunity Fund LP, et al., Appellees.
Appeal from the Texas Business Court, First Division Dallas County, Texas Honorable Bill Whitehill
BRIEF FOR APPELLEES
ORAL ARGUMENT REQUESTED
SUSMAN GODFREY L.L.P. Pro hac vice forthcoming:
Stephen Shackelford, Jr. Marc M. Seltzer State Bar No. 24062998 (TX) mseltzer@susmangodfrey.com sshackelford@susmangodfrey.com Bryan Caforio 1000 Louisiana Street, Ste 5100 bcaforio@susmangodfrey.com Houston, Texas 77002 Lindsey Godfrey Eccles Telephone: (713) 651-9366 leccles@susmangodfrey.com Facsimile: (713) 654-6666 Sarah Hannigan shannigan@susmangodfrey.com
Attorneys for Appellees Table of Contents
TABLE OF CONTENTS ........................................................................ II
INDEX OF AUTHORITIES ................................................................ III
ISSUES PRESENTED ............................................................................ 1
STATEMENT OF FACTS ...................................................................... 2
ARGUMENT ............................................................................................ 8
I. THE BUSINESS COURT PROPERLY APPLIED RULE 120A TO EVALUATE APPELLANTS’ CONSENT TO JURISDICTION .............................................. 11
A. The plain terms of Rule 120a include predecessor proceedings in the same dispute. .............................................................................. 12
B. Appellants waived their challenge to personal jurisdiction when they filed answers and moved to dismiss in the Original Action without entering special appearances. ............................................. 16
C. The dismissal of the Dallas proceeding does not reverse Appellants’ consent to personal jurisdiction in Texas. ..................... 20
D. Public policy favors affirmance to prevent litigants who consented to jurisdiction in the same dispute from later evading the jurisdiction of Texas courts. ............................................................. 22
II. APPELLANTS ARE ESTOPPED FROM REVERSING THEIR POSITION ON JURISDICTION ........................................................................................ 25
III. THE FACTUAL RECORD SHOWS APPELLANTS’ SUBSTANTIAL CONTACTS WITH TEXAS .......................................................................... 29
CONCLUSION ....................................................................................... 34
ii Index of Authorities
Cases Page(s)
BMC Software Belgium, N.V. v. Marchand, 83 S.W.3d 789 (Tex. 2002) .................................................................. 30
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) ................................................................. 17, 25, 32
Cadena Comercial USA Corp. v. Tex. Alcoholic Beverage Comm’n, 518 S.W.3d 318 (Tex. 2017) ................................................................ 16
Carlile Bancshares, Inc. v. Armstrong, No. 02-14-00014-CV, 2014 WL 3891658 (Tex. App.—Fort Worth Aug. 7, 2014, no pet.) ............................................................... 33
City of San Antonio v. Hardee, 70 S.W.3d 207 (Tex. App.—San Antonio 2001, no pet.) ..................... 26
Exito Elecs. Co., Ltd. v. Trejo, 142 S.W.3d 302 (Tex. 2004) ................................................................ 18
Ford Motor Co. v. Cejas No. 09-16-00280-CV, 2018 WL 1003791 (Tex. App.— Beaumont Feb. 22, 2018, no pet.) ................................................. 19, 20
George Fleming & Fleming & Associates, L.L.P. v. Wilson, 694 S.W.3d 186 (Tex. 2024), reh’g denied (Aug. 30, 2024) ........................................................................................... 21, 25, 28, 29
Glencoe Capital Partners II, L.P. v. Gernsbacher, 269 S.W.3d 157 (Tex. App.—Fort Worth 2008, no pet.)..................... 32
In re Bridgestone Americas Tire Operations, LLC, 459 S.W.3d 565 (Tex. 2015) ................................................................ 16
In re Estate of Washington, 262 S.W.3d 903 (Tex. App.—Texarkana 2008, no pet.) ..................... 23
iii M&F Worldwide Corp. v. Pepsi-Cola Metro. Bottling Co., Inc., 512 S.W.3d 878 (Tex. 2017) ................................................................ 30
Massachusetts Bay Company v. Adkins 615 S.W.3d 580 (Tex. App.—Houston [1st Dist.] 2020, no pet.) ......................................................................................... 13, 14, 15
Michiana Easy Livin’ Country, Inc. v. Holten, 168 S.W.3d 777 (Tex. 2005) ................................................................ 26
Nationwide Distribution Services, Inc. v. Jones, 496 S.W.3d 221 (Tex. App.—Houston [1st Dist.] 2016, no pet.) ..................................................................................................... 17
Retamco Operating, Inc. v. Republic Drilling Co., 278 S.W.3d 333 (Tex. 2009) .................................................... 30, 32, 33
Rodriguez v. Marcus, 564 S.W.3d 216 (Tex. App.—El Paso 2018, no pet.) ........................... 17
RSR Corp. v. Siegmund, 309 S.W.3d 686 (Tex. App.—Dallas 2010, no pet.) ........................ 7, 17
Rush v. Barrios, 56 S.W.3d 88 (Tex. App.—Houston [14th Dist.] 2001, pet. denied) ..................................................................................... 13, 21, 22
Tex. Rice Land Partners, Ltd. v. Denbury Green Pipeline- Tex., LLC, 381 S.W.3d 465 (Tex. 2012) ................................................................ 23
TGS-NOPEC Geophysical Co. v. Combs, 340 S.W.3d 432 (Tex. 2011) ................................................................ 16
Upjohn Co. v. U.S., 449 U.S. 383 (1981) ............................................................................. 24
Vogel v. Travelers Indem. Co., 966 S.W.2d 748 (Tex. App.—San Antonio 1998, no pet.) ................... 20
iv W. Techs., Inc. v. Omnivations II, L.L.C., 583 S.W.3d 786 (Tex. App.—El Paso 2019, no pet.) ........................... 27
Walden v. Fiore, 571 U.S. 277 (2014) ............................................................................. 30
Waterman Steamship Corp. v. Ruiz 355 S.W.3d 387 (Tex. App.—Houston [1st Dist.] 2011, pet. denied) ........................................................................................... 18, 19
Winnsboro Auto Ventures, LLC v. Santander Consumer USA, Inc., No. 05-17-00895-CV, 2018 WL 1870771, at *7 (Tex. App.- Dallas Apr. 19, 2018, no pet.) ............................................................. 25
Rules
Rule 120a ......................................................................................... passim
v Issues Presented
1. Appellants consented to personal jurisdiction in Texas by
filing answers and a motion to dismiss in a “virtually identical” Original
Action—without filing special appearances. Did Appellants waive their
personal jurisdiction challenge in the Business Court Action, which
involves the same allegations and claims against Appellants arising from
the same disputed transaction?
2. Appellants argued in the Original Action that the Texas
federal forum-selection clause applied to them, and achieved dismissal
on that basis. Parties that agree to a Texas forum-selection clause
consent to personal jurisdiction in Texas. Are Appellants estopped from
now taking the exact opposite position in the Business Court Action?
3. Appellants invested in the Texas partnership at issue
and/or received hundreds of millions of dollars in shares from the sale of
the partnership’s Texas oil assets to another Texas company. Do
Appellants have minimum contacts with Texas to establish personal
jurisdiction?
1 Statement of Facts
Appellees were minority investors in Primexx, a successful oil
company operating in the Delaware Basin. 1 Blackstone Inc., one of the
world’s largest private equity firms, became the majority owner of
Primexx through its subsidiaries BPP HoldCo LLC and Appellants.2
Each Appellant is a Blackstone Inc. subsidiary that is the sole member,
managing member, or general partner of the subsidiary below, ending
with BPP HoldCo LLC, the Blackstone operating company for the
Primexx investment.3
In June 2021, an independent third-party valuation firm valued
Primexx Energy Partners at $1.43 billion, making Appellees’
investments worth more than $200 million.4 Blackstone, however,
pushed through a firesale of Primexx’s Texas-based real assets to serve
its own corporate agenda. 5 After receiving a series of lowball offers from
Callon Petroleum Company that the Primexx CEO himself called far too
low, Blackstone informed the Primexx Board of Directors on July 30,
1 CR0004. 2 CR0004–05. 3 CR0011. 4 CR0005. 5 CR0028–29.
2 2021, that it was planning to sell Primexx to Callon for less than half of
Primexx’s recently-appraised value.6 Blackstone thereafter executed a
forced drag-along transaction—it informed the Board on a Friday and
demanded that the directors approve the sale the next business day. 7
Blackstone controlled five of the nine seats on the Board, which approved
the sale on August 2. 8 Appellants received hundreds of millions in
proceeds, but Appellees’ $200 million investment was almost completely
wiped out.9
Appellees filed suit against Appellants, BPP HoldCo LLC, Primexx
Energy Corporation, and M. Christopher Doyle in Dallas county in
December 2022 (the “Original Action”). 10 Appellants filed answers and
moved to dismiss based on a forum-selection clause in the Partnership
Agreement at issue, which specified the federal court located in Dallas,
Texas.11 No Appellant filed a special appearance. 12 Instead, in their
6 CR0005. 7 CR005–06. 8 CR0006. 9 CR0006; CR0475–549. 10 CR1049. 11 CR1049. Appellees first filed in state court, not federal court, because there is no
federal subject matter jurisdiction. Appellees’ claims arise under Texas law. Appellants are citizens of at least Delaware and New York, and Appellees (which are limited partnerships) are citizens of several states, including New York, through the citizenship of the limited partners. CR0010–15. 12 CR1049.
3 motion to dismiss, Appellants argued that they could enforce the forum-
selection clause—despite not being signatories to the Partnership
Agreement—because the forum-selection clause “is undeniably broad
and indisputably encompasses Plaintiffs’ claims” and “must be
enforced.” 13 Appellants further argued that claims against the non-
signatory Appellants fall “within the scope of the forum-selection clause
based on the plain meaning of the provision.”14
The Dallas court granted Appellants’ motion to dismiss. 15 In
response to the court’s decision, Appellees re-filed the same action in the
United States District Court for the Northern District of Texas. Appellees
added Blackstone Inc. executive Angelo Acconcia as a defendant, but
otherwise all claims and causes of action remained the same. 16 The
federal district court sua sponte noted that it appeared to lack subject
matter jurisdiction and that “a federal court’s subject matter jurisdiction
cannot be expanded upon agreement of the parties.”17 The court provided
both parties an opportunity to respond. No Appellants (or any other
13 CR0007. 14 CR0007; CR0182. 15 CR1049. 16 CR1050. 17 CR0008; CR0194.
4 Defendants) responded to the court’s order or provided any evidence or
information that could establish subject matter jurisdiction. 18 The federal
district court dismissed the federal action on July 14, 2023.19
Appellees re-filed the same action in Dallas county on July 31, 2023,
again with the same claims and causes of action against Appellants. This
time, Appellants did enter special appearances. 20 The other Defendants,
including Appellants’ subsidiary BPP HoldCo LLC, filed an unopposed
motion to transfer to the 298th Judicial District, where the Original
Action had been pending. 21 The transferring Defendants argued that the
action “alleg[es] the same claims against the same parties arising out of
the same transaction as the First Action that the 298th District Court
previously dismissed,” noting that “many of the allegations in the instant
action are word-for-word verbatim [] in the First Action.”22 The 298th
District Court later accepted the transfer but did not take any further
action on the case.
In an effort to increase efficiency, Appellees filed an unopposed
18 CR0008. 19 CR0009. 20 CR0009. 21 CR1050. 22 CR1051.
5 Notice of Removal to the Business Court on September 27, 2024.23 After
the Business Court raised the question of whether it had jurisdiction over
removals of actions filed before September 1, 2024, the parties agreed to
dismiss the removed action without prejudice so that Appellees could re-
file it in the Business Court in the first instance. 24 The parties entered
into a Rule 11 agreement providing that all discovery and pleadings from
the Dallas action would be moved over to the Business Court. 25
Appellees filed the instant lawsuit on October 25, 2024 (the
“Business Court Action”).26 In an order dated January 17, 2025, and an
Opinion and Order dated February 10, 2025, the Business Court denied
Appellants’ special appearances. The Business Court concluded that the
Business Court Action was “substantially identical” to the Original
Action in which Appellees consented to personal jurisdiction:
This Original Petition is substantially identical to the petition in the Third Action that the parties previously tried to remove here, which the nonspecially appearing defendants had in turn stated “alleg[ed] the same claims against the same parties arising out of the same transaction as the First Action.” Accordingly, the active pleading here asserts the same causes of action arising out of the
23 CR1051. 24 CR1050. 25 CR0010. 26 CR1052.
6 same transaction as the First Action against the same Blackstone Defendants. 27
The Business Court noted that “personal jurisdiction is a ‘waivable
right,’” so that once a party consents to jurisdiction, “the trial court’s
exercise of personal jurisdiction over it does not violate due process even
in the absence of contacts with Texas.” 28 The Business Court found that
Appellants had entered a general appearance in the Original Action “by
seeking affirmative action from the court and filing an answer without
filing special appearances.”29
The Business Court then turned to the question of whether
Appellants consented to jurisdiction in the Business Court Action by
failing to file special appearances in the Original Action. The Court found
that Appellants “voluntarily appeared and chose to litigate claims arising
from the Callon transaction” in Texas, and that the Business Court
Action was “essentially the same action” as the Original Action. 30 The
Business Court thus held that Appellants’ general appearance in the
27 CR1052. 28 CR1066–67 (quoting RSR Corp. v. Siegmund, 309 S.W.3d 686, 704 (Tex. App.—
Dallas 2010, no pet.). 29 CR1067. 30 CR1071; CR1075.
7 Original Action “waived their right to object to personal jurisdiction
here.”31
Argument
The Business Court properly determined that Appellants are
subject to personal jurisdiction in Texas for at least three reasons. First,
Appellants consented to personal jurisdiction by filing answers and
moving to dismiss—without filing special appearances—in a Dallas court
in the Original Action, which involved the exact same claims at issue
here. Second, Appellants are estopped from now arguing that a Texas
forum-selection clause does not apply to them after successfully arguing
to the Dallas court that Appellants are subject to that same Texas forum-
selection clause, which confers personal jurisdiction in Texas. Third,
Appellants’ participation in the sale of the Texas oil assets of a Texas
company to another Texas company—and receipt of hundreds of millions
of dollars of shares from that sale—is sufficient to confer personal
jurisdiction in this state. This Court should affirm the Business Court’s
thorough and well-reasoned Opinion.
31 CR1075.
8 First, Appellants consented to personal jurisdiction by filing an
answer and moving to dismiss in the Original Action without filing
special appearances. The Original Action involved the exact same claims
against Appellants—as the Business Court concluded, “the active
pleading here asserts the same causes of action arising out of the same
transaction as the First Action against the same Blackstone
Defendants.” 32 The Business Court went so far as to call them “virtually
identical.”33 And Appellants’ subsidiary BPP HoldCo LLC agrees. In a
motion to transfer, BPP HoldCo LLC and other Defendants argued that
the second petition “alleg[es] the same claims against the same parties
arising out of the same transaction as the First Action,” noting that
“many of the allegations in the instant action are word-for-word
verbatim.” 34 It is black-letter law that a party waives its jurisdictional
challenge by appearing without filing a special appearance, as Appellants
did here.
Second, Appellants are estopped from now arguing that the Texas
courts lack personal jurisdiction after previously successfully arguing the
32 CR1052. 33 CR1078. 34 CR1051.
9 opposite. Since Appellants previously asked a Texas court for, and
received, affirmative relief in another stage of this case, the doctrine of
judicial estoppel prevents Appellants from taking the opposite position to
their advantage. Appellants asked the Dallas court to dismiss the
Original Action based on their argument that the forum-selection clause
in the Partnership Agreement at issue applied to each of the Appellants.
Appellants do not—and cannot—contest that the applicability of a Texas
forum-selection clause is sufficient to confer personal jurisdiction in
Texas, and the Dallas court granted Appellants’ motion to dismiss. But
now, after successfully arguing that the forum-selection clause applies to
them, Appellants now argue the exact opposite and ask this Court to find
that the forum-selection clause actually does not apply to them. After
receiving affirmative relief based on the applicability of the forum-
selection clause, Appellants are estopped from reversing their position.
Third, this Court should affirm the Business Court’s opinion on the
alternative basis that Appellants’ significant contacts with Texas are
sufficient to confer jurisdiction on their own. Appellants’ direct
involvement in the sale of the Texas oil assets of a Texas company to
another Texas company confers jurisdiction on its own. The record
10 demonstrates that each Appellant invested in the Texas partnership
and/or received hundreds of millions of dollars from the sale of real Texas
assets. That surpasses the threshold for minimum contacts with the state
of Texas related to this dispute.
The courts of Texas have personal jurisdiction over Appellants, and
this Court should affirm.
I. The Business Court Properly Applied Rule 120a to Evaluate Appellants’ Consent to Jurisdiction
In a 34-page Opinion, the Business Court properly considered the
text of Tex. R. Civ. P. 120a and applicable precedent to conclude that
Appellants waived any personal jurisdiction challenges to the Business
Court Action. The text of Rule 120a refers to “an entire proceeding,”
which incorporates the Business Court Action here. Appellants plainly
consented to the jurisdiction of the courts of Texas by filing answers and
moving to dismiss. Appellants now try to argue that their waiver was
somehow reversed by the dismissal of the Original Action, or that public
policy counsels in favor of permitting Appellants to now evade the
jurisdiction of Texas courts after choosing to willingly participate in
Texas proceedings before. Both arguments fail.
11 A. The plain terms of Rule 120a include predecessor proceedings in the same dispute.
Rule 120a, which refers to an “entire proceeding,” includes
substantially identical actions that include the same claims against the
same parties. Tex. R. Civ. P. 120a provides that a party may enter a
special appearance “for the purpose of objecting to the jurisdiction of the
court over the person or property of the defendant on the ground that
such party or property is not amenable to process issued by the courts of
this State.” The special appearance “may be made as to an entire
proceeding or as to any severable claim involved therein.” (emphasis
added).
Here, “an entire proceeding” refers to both the Original Action and
the Business Court Action. As the Business Court found, the petitions in
the Original Action and the Business Court Action are “virtually
identical”—they involve the same claims against Appellants based on the
same facts. 35 The changes in venue between courts in Texas—originally
due to Appellants’ insistence on proceeding in federal court despite the
clear lack of subject matter jurisdiction—does not change the fact that
35 CR1052; CR1078.
12 the Original Action and the Business Court Action are part of the same
proceeding. The Business Court correctly determined that “[b]ut for the
cause number and the particular court, this action is essentially the same
action as the first one filed on December 12, 2022 . . . in which Blackstone
Defendants made a general appearance.” 36 The Original Action and the
Business Court Action are so similar that Appellants do not even attempt
to point out a single difference that could possibly affect their consent to
jurisdiction.
The Business Court is correct that Massachusetts Bay Company v.
Adkins demonstrates that “an entire proceeding” is not limited to one
specific cause number.37 See 615 S.W.3d 580 (Tex. App.—Houston [1st
Dist.] 2020, no pet.); see also Rush v. Barrios, 56 S.W.3d 88, 104 (Tex.
App.—Houston [14th Dist.] 2001, pet. denied). In Massachusetts Bay, a
defendant filed an answer in an underlying Jefferson County personal
injury case without filing a special appearance. The case was transferred
to an MDL court where the defendant first attempted to contest personal
jurisdiction. 38
36 CR1075. 37 CR1071. 38 CR1072 (citing 615 SW.3d at 592).
13 The First District held that the underlying action and the MDL
action were the same “proceeding” for purposes of Rule 120a, so the
defendant waived a jurisdictional challenge by filing an answer in the
underlying case. The court noted that “the proceeding in the MDL court
in Harris County was simply a continuation of the proceeding in
Jefferson County, albeit in a different court in a different county.” 615
S.W.3d at 599. The same is true here—the Business Court Action is
“simply a continuation of the proceeding” in Dallas county in the Original
Action.
Appellants’ attempt to narrow Massachusetts Bay is unfounded.
Appellants claim that Massachusetts Bay applies only to cases in which
a cause number is directly “transferred or removed” to another court in
Texas, and argue that here the Business Court Action was “directly filed”
in the Business Court.39 But the Massachusetts Bay court concluded more
generally that “[t]he purpose of a special appearance, however, is to
contest the ability of all courts in the forum state—not a particular
district court—to exercise personal jurisdiction over a defendant,” so
“[w]hat is relevant is that, by filing its answer, unconditioned by a special
39 Appellants’ Br. at 19.
14 appearance, Massachusetts Bay acknowledged that the case was
properly pending before a Texas court.” Id. at 599–600. That same
analysis should govern here. Appellants “acknowledged that the case was
properly pending before a Texas court” by filing answers and moving to
dismiss in the Original Action. A new cause number, or an agreed-upon
procedural re-filing in the Business Court, does not change that
Appellants agreed that the courts of Texas have personal jurisdiction
over Appellants with respect to this dispute.
Appellants’ statutory construction argument similarly fails.
Appellants contend that because Rule 120a provides that “[a] special
appearance may be made as to an entire proceeding or as to any severable
claim involved therein,” the use of “or” limits “entire proceeding” to one
specific cause number.40 But Appellants have not pointed to any
authority holding that Rule 120a’s reference to an “entire proceeding” is
limited to one specific cause number.
Appellants further do not address the fact that, if the Legislature
intended to restrict Rule 120a to a specific cause number, the Legislature
could have explicitly done so—for example, by using the term “cause,”
40 Appellants’ Br. at 17.
15 “cause number,” or another term that would have more specifically
referenced only one particular cause number in a proceeding. Appellants
ask this Court to disregard the most reasonable reading of the statute:
that “proceeding” does not mean only a specific cause number. 41 See, e.g.,
Cadena Comercial USA Corp. v. Tex. Alcoholic Beverage Comm’n, 518
S.W.3d 318, 327 (Tex. 2017) (“If an undefined word used in a statute has
multiple and broad definitions, we presume—unless there is clear
statutory language to the contrary—that the Legislature intended it to
have equally broad applicability.”); TGS-NOPEC Geophysical Co. v.
Combs, 340 S.W.3d 432, 439 (Tex. 2011) (“We presume that the
Legislature chooses a statute’s language with care, including each word
chosen for a purpose, while purposefully omitting words not chosen.”).
B. Appellants waived their challenge to personal jurisdiction when they filed answers and moved to dismiss in the Original Action without entering special appearances.
Appellants consented to personal jurisdiction in Texas for purposes
of this dispute when they failed to file special appearances and proceeded
41 While the Texas Rules of Civil Procedure are promulgated by the Texas Supreme
Court and are not embodied in a statute, the Supreme Court has instructed that “[w]hen we analyze Texas’s procedural rules, we apply the same rules of construction that govern the interpretation of statutes.” In re Bridgestone Americas Tire Operations, LLC, 459 S.W.3d 565, 569 (Tex. 2015).
16 to file answers and a motion to dismiss in the Original Action. Rule 120a
provides that a special appearance “shall be made by sworn motion filed
prior to motion to transfer venue or any other plea, pleading, or motion.”
The rule states that “[e]very appearance, prior to judgment, not in
compliance with this rule is a general appearance.” It is black-letter law
that a party waives any jurisdictional challenge by entering a pleading
such as an answer without filing a special appearance. See Nationwide
Distribution Services, Inc. v. Jones, 496 S.W.3d 221, 224 (Tex. App.—
Houston [1st Dist.] 2016, no pet.) (“A defendant that does not strictly
comply with the procedural requirements of Rule 120a, including the
due-order-of-pleading and due-order-of-hearing requirements, waives its
jurisdictional challenge and enters a general appearance.”); Rodriguez v.
Marcus, 564 S.W.3d 216, 219 (Tex. App.—El Paso 2018, no pet.) (same).42
Notably, the Texas Supreme Court has broadly framed the ways in
which a party may consent to the jurisdiction of the Texas courts. A party
waives a jurisdictional challenge and enters a general appearance “when
it (1) invokes the judgment of the court on any question other than the
42 As the Business Court explained at CR1066, “personal jurisdiction is a ʻwaivable
right’ and [a defendant] may give ʻexpress or implied consent to the personal jurisdiction of the court.’” RSR Corp. v. Siegmund, 309 S.W.3d 686, 704 (Tex. App.— Dallas 2010, no pet.) (quoting Burger King Corp., 471 U.S. at 473 n.14).
17 court’s jurisdiction, (2) recognizes by its acts that an action is properly
pending, or (3) seeks affirmative action from the court.” Exito Elecs. Co.,
Ltd. v. Trejo, 142 S.W.3d 302, 304 (Tex. 2004). Here, Appellants
“recognized by [their] acts that an action is properly pending” in Texas
by answering in the Original Action. Appellants further sought
“affirmative action from the court” by invoking the federal forum-
selection clause in their favor, all without contesting personal jurisdiction
or filing a special appearance.
Appellants’ reliance on Waterman Steamship Corp. v. Ruiz is
misplaced. See 355 S.W.3d 387, 400 (Tex. App.—Houston [1st Dist.] 2011,
pet. denied). Appellants’ alterations to the quotation at note 45 obscure
the fact that the two cases at issue in Waterman Steamship—the Hicks
case and the Ruiz case—involved two different plaintiffs. 43 In addition to
the first and second actions involving two different plaintiffs, the first
(different) plaintiff had also voluntarily dismissed its original action. The
court based its waiver finding on the fact that “any waiver in the Hicks
case was extinguished by the nonsuit and cannot operate as a basis for
denying Waterman’s and Maersk’s special appearances in the Ruiz case.”
43 Appellants’ Br. at 22.
18 See 355 S.W.3d at 399. There are no such distinctions here, where the
Original Action and the Business Court action involve the same plaintiffs
and the exact same claims against Appellants.
Ford Motor Co. v. Cejas, which involved a forum non conveniens
dismissal in favor of the courts of Mexico followed by a separate action in
Mexico, is also distinguishable. See No. 09-16-00280-CV, 2018 WL
1003791, at *5 (Tex. App.—Beaumont Feb. 22, 2018, no pet.). In Ford
Motor, an MDL dismissed an individual personal injury suit based on
forum non conveniens in favor of the courts of Mexico. When the plaintiff
re-filed seven years later in Texas, the court found that the defendants
had not waived a jurisdictional challenge. Id. at *5. In that case, however,
the MDL court’s forum non conveniens order contained a specific “return
jurisdiction clause” regarding how the case would proceed if plaintiff re-
filed in Texas: “If Plaintiffs invoke this return jurisdiction clause and re-
file in the State of Texas . . . this Court shall at that time have jurisdiction
to determine whether the conditions for invoking the return jurisdiction
clause have been met.” Id. The court thus explicitly contemplated re-
evaluating the new action on jurisdictional grounds, including based on
the status of the case proceeding in Mexico. Id. at *1. The court also did
19 not observe or discuss potential similarities between the original cause of
action and the Texas action seven years later. Here, however, there has
been a continuous proceeding within Texas since December 2022, with
“virtually identical” causes of action throughout.
C. The dismissal of the Dallas proceeding does not reverse Appellants’ consent to personal jurisdiction in Texas.
The Dallas court’s dismissal of the Original Action based on
Appellants’ invocation of the federal forum-selection clause does not
reverse Appellants’ consent to personal jurisdiction in Texas. Appellants
cite no authority for their sweeping (and incorrect) proposition that “a
dismissal without prejudice terminates the effect of any prior filings.”44
There are numerous examples to the contrary. For example, “the
voluntary withdrawal or dismissal of claims from an earlier suit will not
preclude the operation of res judicata to bar their assertion in a
subsequent suit, even where such claims are dismissed without
prejudice.” Vogel v. Travelers Indem. Co., 966 S.W.2d 748, 752 (Tex.
App.—San Antonio 1998, no pet.) (emphasis added). Parties may also be
judicially estopped from taking a contrary position in a later action after
44 Appellants’ Br. at 24.
20 successfully obtaining dismissal based on their previous representations
to the court. See, e.g., George Fleming & Fleming & Associates, L.L.P. v.
Wilson, 694 S.W.3d 186, 194 (Tex. 2024), reh’g denied (Aug. 30, 2024).
Rush v. Barrios, in which the Fourteenth District found that a
defendants’ appearance in a dismissed suit waived a jurisdictional
challenge in a later suit, is instructive. 56 S.W.3d 88, 92 (Tex. App.—
Houston [14th Dist.] 2001, pet. denied). Appellant, a lawyer, filed a plea
in intervention in the products liability suit of a previous client, seeking
one-third of any settlement amount awarded to the client. Id. at *104.
The lawyer appeared in that suit in Texas without filing a special
appearance and later dismissed the plea in intervention without
prejudice. Id. After settling the products liability suit, the former client
sued the lawyer in a declaratory judgment action to determine the
allocation of attorneys’ fees. Id. The lawyer then entered a special
appearance challenging jurisdiction in Texas.
The Fourteenth District held that the lawyer waived any challenge
to personal jurisdiction in Texas based on his general appearance in the
prior products liability suit—even though the prior plea in intervention
was dismissed without prejudice and all of the events occurred in a totally
21 different action. The court noted that the lawyer “did not enter a special
appearance in the underlying suit, but waited until this declaratory
judgment was filed to file a special appearance.” Id. Without filing a
special appearance, the lawyer sought “to invoke the authority of the
court” by filing a plea in intervention, and thus “waived any objection to
personal jurisdiction” in the later suit. Id. at *104–05. That waiver
applied even though the plea in intervention was dismissed without
prejudice. The same is true here—the Dallas court’s dismissal of the
Original Action due to Appellants’ invocation of the federal forum-
selection clause does not alter the fact that Appellants consented to
jurisdiction by answering and moving to dismiss, which applies to the
continuation of the proceeding in the Business Court Action.
D. Public policy favors preventing litigants who consented to jurisdiction in the same dispute from later evading the jurisdiction of Texas courts.
Appellants claim that public policy favors reversal because
purportedly (1) “the business court’s opinion was not clear about the
degree of ‘relatedness’ needed to establish consent” and (2) the court did
not set a specific standard for the time between cases that can lead to a
22 finding that the cases are sufficiently related. 45 The Business Court’s
decision does not contain either alleged issue, and policy considerations—
to the extent this Court considers them—strongly support finding
jurisdiction here.
First, Appellants take issue with the fact that, in resolving the
dispute before it, the Business Court purportedly “did not detail whether
the parties and causes of action must be identical between the earlier and
later cases” in all situations.46 But any such determination of a broader
rule was unnecessary to the Business Court’s resolution of the specific
facts of this case. The Business Court found that the Original Action and
the Business Court Action were “virtually identical.”47 As such, there was
no need for the Business Court to consider whether the parties and
causes of actions must be identical in all circumstances. 48
45 Appellants’ Br. at 25–26. 46 Appellants’ Br. at 25–26. 47 CR1078. 48 In fact, such a broad resolution—creating a rule applicable to other parties when
unnecessary to the resolution of the dispute before the court—would have exceeded the proper scope of the Business Court’s authority. See, e.g., In re Estate of Washington, 262 S.W.3d 903, 905 (Tex. App.—Texarkana 2008, no pet.) (“We are prohibited from issuing an advisory opinion, the distinctive feature of which is that it decides an abstract question of law without binding the parties . . . Thus, we emphasize that our decision is based solely on the appeal before us.”); Tex. Rice Land Partners, Ltd. v. Denbury Green Pipeline-Tex., LLC, 381 S.W.3d 465, 466 (Tex. 2012) (J. Wainwright and J. Johnson, concurring) (“I also believe that in providing guidance we should take care not to issue pronouncements exceeding the scope of the facts in
23 Second, Appellants criticize the Business Court for not setting
“guidelines for how close in time the pending case must be to the ‘consent’
case to affect a waiver of personal jurisdiction.” 49 But the same issue
applies—how close in time a different, theoretical pending case must be
to the original case to constitute consent is a case-specific inquiry that
was not before the Business Court. Instead, the Business Court
evaluated the particular litigation history in this case, including the
intertwined nature of the relevant actions, and concluded that
Appellants’ consent in the Original Action applied with equal force to the
Business Court Action.
Finally, Appellants then invoke “policy considerations” to support
their argument, but any consideration of “policy considerations” strongly
favors Appellants’ position. The courts of Texas have a specific interest
in ensuring that a party is subject to jurisdiction in Texas when (1) it
consented to personal jurisdiction in a “virtually identical” matter; (2) it
successfully argues it is subject to a Texas forum-selection clause and
Texas choice-of-law provision; and (3) the dispute revolves around that
dispute.”) (quoting the Supreme Court’s conclusion in Upjohn Co. v. U.S., 449 U.S. 383, 386 (1981) that it “decline[s] to lay down a broad rule or series of rules to govern all conceivable future questions”). 49 Appellants’ Br. at 26.
24 party’s gain of hundreds of millions of dollars from the sale of the Texas-
based real oil assets of one Texas company to another Texas company.
See, e.g., Winnsboro Auto Ventures, LLC v. Santander Consumer USA,
Inc., No. 05-17-00895-CV, 2018 WL 1870771, at *7 (Tex. App.—Dallas
Apr. 19, 2018, no pet.) (“Texas has a manifest interest in ensuring ‘a
convenient forum for redressing injuries inflicted by out-of-state actors.’
. . . Furthermore, Texas has an interest in adjudicating the dispute
because the laws of Texas will apply to the contract’s interpretation.”)
(quoting Burger King Corp. v. Rudzewicz, 471 U.S. 462, 473 (1985)).
II. Appellants are Estopped from Reversing their Position on Jurisdiction
The doctrine of judicial estoppel (or quasi-estoppel) prevents
Appellants from claiming Texas courts lack jurisdiction after Appellants
successfully argued that a Texas forum-selection clause applies to them.
“At its most general level, ‘[j]udicial estoppel is a common law doctrine
that prevents a party from assuming inconsistent positions in litigation.’
. . . ‘Its essential function is to prevent the use of intentional self-
contradiction as a means of obtaining unfair advantage.’” George Fleming
& Fleming & Associates, L.L.P. v. Wilson, 694 S.W.3d 186, 191 (Tex.
2024), reh’g denied (Aug. 30, 2024) (citations omitted). In the
25 jurisdictional context, “[e]stoppel is an equitable doctrine which prevents
a party from challenging the trial court’s jurisdiction because the party’s
prior conduct is inconsistent with their claim of lack of jurisdiction.” City
of San Antonio v. Hardee, 70 S.W.3d 207, 213 (Tex. App.—San Antonio
2001, no pet.).
In the Original Action, Appellants moved to dismiss based on a
Texas federal forum-selection clause, thus necessarily consenting to
personal jurisdiction in Texas. Appellants argued that the Texas forum-
selection clause applied to all Appellants (which were non-signatories to
the Partnership Agreement): in their motion to dismiss, Appellants
asserted: “The Forum-Selection Clause is Enforceable as to
Nonsignatories,” and thereby argued that plaintiffs’ claims against
Appellants “can only rely on the Partnership Agreement, thus enabling
the Affiliated Blackstone Defendants [Appellants] to invoke the forum-
selection clause.”50 It is well-established in Texas that consent to a Texas
forum selection clause creates consent to personal jurisdiction in Texas.
See, e.g., Michiana Easy Livin’ Country, Inc. v. Holten, 168 S.W.3d 777,
792 (Tex. 2005) (“Generally, a forum-selection clause operates as consent
50 CR0299–300 (emphasis added).
26 to jurisdiction in [that] forum.”); W. Techs., Inc. v. Omnivations II, L.L.C.,
583 S.W.3d 786, 792 (Tex. App.—El Paso 2019, no pet.) (“Agreeing to a
forum selection clause naming Texas the forum for litigation waives any
objection to lack of personal jurisdiction and makes the party subject to
personal jurisdiction in a Texas court.”). Appellants “invoke[d] the forum-
selection clause” in the Original Action and successfully convinced that
court they were subject to the Texas forum selection clause to succeed on
their motion to dismiss before that court.
But now, in the Business Court Action, Appellants argue the exact
opposite. Specifically, Appellants claim in their special appearance that
Appellants, as non-parties to the Partnership Agreement, did not consent
to—and are not bound by—the Texas forum selection clause. Appellants
argued that non-signatories “‘may be subject to a forum-selection clause’
only in limited circumstances,” and that Appellants (as non-signatories)
“did not consent to the same exclusive jurisdiction” described in the forum
selection clause. 51
Judicial estoppel precludes Appellants from successfully advancing
a total and irreconcilable position to now evade the reach of the same
51 CR0244.
27 Texas courts they previously argued had jurisdiction to grant them relief.
As the Supreme Court recently emphasized, “the party to be estopped
must have obtained a benefit by making a clear and unambiguous
statement that convinced a prior court to adopt a position that
contradicts the party’s current position. The doctrine applies unless,
under the circumstances, the court finds that its application would be
unjust or contrary to the doctrine's underlying purposes.” 52 George
Fleming, 694 S.W.3d at 193.
First, Appellants “prevailed” and gained an advantage by
“persuad[ing] the court to adopt the party’s position and thus grant the
relief that the party sought.” Id. at 191–92. Appellants obtained
dismissal of the Original Action by successfully arguing that they could
enforce the Texas federal forum-selection clause as nonsignatories and
thereby require the case to proceed in the Northern District of Texas.
Second, Appellants’ statement was “clear and unambiguous”: Appellants
argued that “The Forum-Selection Clause is Enforceable as to
Nonsignatories” and that plaintiffs’ claims “enable[ed] the Affiliated
52 Appellants claim that judicial estoppel requires a “sworn” statement. Appellants’
Br. at 34. That is incorrect—as the Texas Supreme Court explained in George Fleming, the requirement is only that the statement was “clear and unambiguous,” not that it was “sworn.” George Fleming, 694 S.W.3d at 193.
28 Blackstone Defendants [Appellants] to invoke the forum-selection
clause.” 53 Third, Appellants’ prior position that they are subject to the
forum selection clause, which confers personal jurisdiction in Texas,
contradicts their new position that Texas courts lack jurisdiction over
Appellants. Finally, the “successful representation” arose “‘in another
phase’ of the same case,” not in the immediate action before the court. Id.
at 192. Appellants are estopped from gaining an advantage in the
Business Court Action by now reversing the position they convinced the
Court to accept in the Original Action.
III. The Factual Record Demonstrates Appellants’ Substantial Contacts with Texas
Appellants’ substantial contacts with Texas provide an alternative
basis for Appellants to fall within the jurisdiction of Texas courts
regarding the Primexx sale. Appellants invested in a Texas partnership
governing the assets of a Texas oil company; exercised control over
Appellants’ subsidiary that operated the Texas oil company; and received
hundreds of millions of dollars from the fire sale of those Texas-based
53 CR0299–300.
29 real oil assets to another Texas-based company. This substantial and
intentional availment of Texas confers personal jurisdiction in Texas.
“Texas’s long-arm statute ‘extends Texas courts’ personal
jurisdiction as far as the federal constitutional requirements of due
process will permit.”‘ M&F Worldwide Corp. v. Pepsi-Cola Metro. Bottling
Co., Inc., 512 S.W.3d 878, 885 (Tex. 2017) (quoting BMC Software
Belgium, N.V. v. Marchand, 83 S.W.3d 789, 795 (Tex. 2002)).
Consequently, once Plaintiffs alleged conduct that falls under the long-
arm statute, the exercise of personal jurisdiction complies with due
process “if the nonresident defendant has ‘minimum contacts’ with the
state and the exercise of jurisdiction ‘does not offend traditional notions
of fair play and substantial justice.’” Id. (quoting Walden v. Fiore, 571
U.S. 277, 283 (2014)). The minimum contacts analysis considers whether
“(1) the defendant purposefully avails itself of conducting activities in the
forum state, and (2) the cause of action arises from or is related to those
contacts or activities.” Retamco Operating, Inc. v. Republic Drilling Co.,
278 S.W.3d 333, 338 (Tex. 2009).
The petition alleges—and the record confirms—that Appellants
purposefully availed themselves of conducting business in Texas and
30 were directly involved with the key facts at issue in this case. Appellants
each either (1) invested hundreds of millions of dollars into Primexx in
exchange for majority control of the board, which resulted in the forced
sale, or (2) received hundreds of millions of dollars in Callon shares as a
result of the forced sale of the Texas-based real oil assets of one Texas
company to another Texas company. For example, the Partnership
Agreement provided that capital for the agreement would be raised
through Appellants Blackstone Energy Partners II LP and Blackstone
Capital Partners VII LP, which the Partnership Agreement defined as
the “Blackstone Investors.” 54 The Term Sheet attached as Annex B to the
Partnership Agreement refers to Appellant Blackstone Energy Partners
II as “Blackstone,” and notes that “Blackstone will control the board of
managers of the Company” and “will have customary drag-along
rights.” 55 It is that exercise of control, and the forced exercise of the drag-
along right, that is at issue in this dispute. Most Appellants jointly and
beneficially owned nearly six million shares of Callon stock after the
forced transaction closed. 56 And several Appellants signed regulatory
54 CR0050. 55 CR0171–73. 56 CR0469–536.
31 filings related to the Callon sale on behalf of BPP HoldCo LLC,
Appellants’ subsidiary that operated the investment. 57
As the Texas Supreme Court described in Moncrief Oil, “the United
States Supreme Court concluded that forming an enterprise in one state
to send payments to a corporation in the forum state was sufficient to
confer specific jurisdiction.” Moncrief Oil Intern. Inc. v. OAO Gazprom,
414 S.W.3d 142, 153 (Tex. 2013) (citing Burger King, 471 U.S. at 468,
478). That is precisely what happened here: Appellants invested in a
Texas business, orchestrated the sale of the Texas-based real property
of that Texas company to another Texas-based company, and accepted
hundreds of millions of dollars in proceeds from Texas. Texas courts
routinely find that direct involvement in similar Texas-based corporate
disputes is sufficient to confer personal jurisdiction. See, e.g., Glencoe
Capital Partners II, L.P. v. Gernsbacher, 269 S.W.3d 157 (Tex. App.—
Fort Worth 2008, no pet.) (holding that non-resident directors making
misrepresentations on remote board meetings involving Texas residents
was sufficient to confer jurisdiction); Carlile Bancshares, Inc. v.
Armstrong, No. 02-14-00014-CV, 2014 WL 3891658 (Tex. App.—Fort
57 CR0537–0549.
32 Worth Aug. 7, 2014, no pet.) (holding that the court had personal
jurisdiction over two directors of a Colorado-based company due to those
directors’ involvement in a merger transaction between the Colorado
company and a Texas company).
The exercise of jurisdiction over Appellants, each of which received
substantial benefits from purposefully conducting business in Texas,
does not offend traditional notions of fair play and substantial justice.
Once the minimum contacts requirements are satisfied, it is “rare” for
the exercise of personal jurisdiction to fail to comply with the
requirement of fair play and substantial justice. Retamco, 278 S.W.3d at
341. And black-letter law provides that personal jurisdiction does not
require the defendant to have physically set foot in the state of Texas. In
Retamco, the Texas Supreme Court concluded that “while [the
defendant] may not have actually entered the state to purchase this
real property, ‘[j]urisdiction . . . may not be avoided merely because the
defendant did not physically enter the forum state.’” 278 S.W.3d at 339
(Tex. 2009). Appellants’ substantial availment of the state of Texas to
make hundreds of millions of dollars off the sale of Texas-based real oil
assets confers personal jurisdiction.
33 Conclusion
Because Appellants consented to personal jurisdiction in Texas, are
estopped from contesting personal jurisdiction in Texas, and purposefully
availed themselves of the benefits of doing business in Texas to make
hundreds of millions of dollars from selling the Texas-based real oil
assets at issue in this dispute, Appellees respectfully request that this
Court affirm the January 17, 2025 and February 10, 2025 Opinions and
Orders of the Business Court.
Dated: May 29, 2025 Respectfully submitted,
SUSMAN GODFREY L.L.P.
By: /s/ Stephen Shackelford, Jr. Stephen Shackelford, Jr. State Bar No. 24062998 (TX) sshackelford@susmangodfrey.com SUSMAN GODFREY L.L.P. 1000 Louisiana Street, Suite 5100 Houston, Texas 77002 Telephone: (713) 651-9366 Facsimile: (713) 654-6666
Marc M. Seltzer (pro hac vice forthcoming) State Bar No. 54534 (CA) mseltzer@susmangodfrey.com Bryan Caforio (pro hac vice forthcoming) State Bar No. 261265 (CA)
34 bcaforio@susmangodfrey.com SUSMAN GODFREY L.L.P. 1900 Avenue of the Stars, Suite 1400 Los Angeles, CA 90067 Telephone: (310) 789-3100 Facsimile: (310) 789-3150
Lindsey Godfrey Eccles (pro hac vice forthcoming) State Bar No. 33566 (WA) leccles@susmangodfrey.com SUSMAN GODFREY L.L.P. 401 Union Street, Suite 3000 Seattle, WA 98101 Telephone: (206) 516-3880 Facsimile: (206) 516-3883
Sarah Hannigan (pro hac vice forthcoming) State Bar No. 5961248 (NY) shannigan@susmangodfrey.com SUSMAN GODFREY L.L.P. One Manhattan West New York, NY 10001 Telephone: (212) 336-8330 Facsimile: (212) 336-8340
Attorneys for Appellees
35 Certificate of Service
This is to certify that on May 29, 2025, a true and correct copy of
the above and foregoing instrument was served on all counsel of record
via eFileTexas.
/s/ Stephen Shackelford, Jr. Stephen Shackelford, Jr.
Certificate of Compliance
I certify that this Brief complies with the requirements of Tex. R.
App. P. 9.4, including Rule 9.4(i)(2). This Brief contains 6,472 words.
/s/ Stephen Shackelford, Jr. Stephen Shackelford, Jr.
36 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.
Stephen Shackelford on behalf of Stephen Shackelford Bar No. 24062998 sshackelford@susmangodfrey.com Envelope ID: 101411718 Filing Code Description: Brief Requesting Oral Argument Filing Description: Brief For Appellees Oral Argument Requested Status as of 5/30/2025 8:53 AM CST
Associated Case Party: Blackstone Holdings III LP, et al.
Name BarNumber Email TimestampSubmitted Status
David S.Coale dcoale@lynnllp.com 5/29/2025 7:05:49 PM SENT
Christopher JSchwegmann cschwegmann@lynnllp.com 5/29/2025 7:05:49 PM SENT
Christopher W.Patton cpatton@lynnllp.com 5/29/2025 7:05:49 PM SENT
Kay Ridenour kridenour@lynnllp.com 5/29/2025 7:05:49 PM SENT
Scott Smoot ssmoot@lynnllp.com 5/29/2025 7:05:49 PM SENT
Kyle A.Gardner kgardner@lynnllp.com 5/29/2025 7:05:49 PM SENT
Kerri Jones kjones@lynnllp.com 5/29/2025 7:05:49 PM SENT
Jessica Cox jcox@lynnllp.com 5/29/2025 7:05:49 PM SENT
Yaman Desai ydesai@lynnllp.com 5/29/2025 7:05:49 PM SENT
Gina Flores gflores@lynnllp.com 5/29/2025 7:05:49 PM SENT
Julie Archuleta jarchuleta@lynnllp.com 5/29/2025 7:05:49 PM SENT
Associated Case Party: Primexx Energy Opportunity Fund, LP., et al.
Name BarNumber Email TimestampSubmitted Status
Bryan Caforio bcaforio@susmangodfrey.com 5/29/2025 7:05:49 PM SENT
Sarah Hannigan sHannigan@susmangodfrey.com 5/29/2025 7:05:49 PM SENT
Lindsey Eccles leccles@susmangodfrey.com 5/29/2025 7:05:49 PM SENT
Jeremy Fielding jeremy.fielding@kirkland.com 5/29/2025 7:05:49 PM SENT
Zack Ewing zack.ewing@kirkland.com 5/29/2025 7:05:49 PM SENT
Roger Cowie roger.cowie@troutman.com 5/29/2025 7:05:49 PM SENT
Taylor Levesque Taylor.Levesque@troutman.com 5/29/2025 7:05:49 PM SENT
Laura Brigham laura.brigham@kirkland.com 5/29/2025 7:05:49 PM SENT 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.
Stephen Shackelford on behalf of Stephen Shackelford Bar No. 24062998 sshackelford@susmangodfrey.com Envelope ID: 101411718 Filing Code Description: Brief Requesting Oral Argument Filing Description: Brief For Appellees Oral Argument Requested Status as of 5/30/2025 8:53 AM CST
Associated Case Party: Primexx Energy Opportunity Fund, LP., et al.
Laura Brigham laura.brigham@kirkland.com 5/29/2025 7:05:49 PM SENT
Michelle Williams mwilliams@susmangodfrey.com 5/29/2025 7:05:49 PM SENT
Josephine Wang jwang@susmangodfrey.com 5/29/2025 7:05:49 PM SENT
Stephen Shackelford SShackelford@susmangodfrey.com 5/29/2025 7:05:49 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Theressa Washington theressa.washington@troutman.com 5/29/2025 7:05:49 PM SENT