Origin Bank v. Aero, L.L.C., JPS Aviation, L.L.C., K. Paul Bullock, and Margaret L. Bullock

CourtLouisiana Court of Appeal
DecidedApril 10, 2024
Docket55,533-CW
StatusPublished

This text of Origin Bank v. Aero, L.L.C., JPS Aviation, L.L.C., K. Paul Bullock, and Margaret L. Bullock (Origin Bank v. Aero, L.L.C., JPS Aviation, L.L.C., K. Paul Bullock, and Margaret L. Bullock) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Origin Bank v. Aero, L.L.C., JPS Aviation, L.L.C., K. Paul Bullock, and Margaret L. Bullock, (La. Ct. App. 2024).

Opinion

Judgment rendered April 10, 2024. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 55,533-CW

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

ORIGIN BANK Applicant

versus

JPS AERO, L.L.C., JPS AVIATION, Respondent L.L.C., K. PAUL BULLOCK, AND MARGARET L. BULLOCK

On Application for Writs from the Fourth Judicial District Court for the Parish of Ouachita, Louisiana Trial Court No. 2020-1228

Honorable Robert C. Johnson, Judge

OFFICE OF W. KYLE GREEN, LLC Counsel for Applicant By: William Kyle Green

DELAWARE REGISTRY LTD Agent for JPS Aero, LLC

JASON P. BULLOCK Agent for JPS Aviation, LLC

SHOTWELL, BROWN, & SPERRY, APLC Counsel for Respondent, By: Clarence Allan Martin, III K. Paul Bullock

MARGARET BULLOCK In Proper Person

Before COX, STEPHENS, and ELLENDER, JJ. STEPHENS, J.,

This writ grant to docket arises from the Fourth Judicial District,

Ouachita Parish, the Honorable Robert C. Johnson, judge, presiding.

Plaintiff, Origin Bank, seeks review of the trial court’s judgment denying its

motion for partial summary judgment in its action to collect on a deficiency

judgment from defendant, K. Paul Bullock, a commercial guarantor for the

principal debtor, JPS Aero, L.L.C. For the following reasons, we grant the

writ, reverse the trial court’s judgment denying partial summary judgment,

and render judgment granting summary judgment in favor of Origin Bank.

FACTS AND PROCEDURAL HISTORY

On November 22, 2013, Jason Paul Bullock, as manager and member

of JPS Aviation, L.L.C. (“JPS Aviation”), executed and signed an Aircraft

Security Agreement wherein JPS Aero, L.L.C. (“JPS Aero”) was identified

as the debtor/borrower and assignor/guarantor. JPS Aero assigned a security

interest in collateral to secure its indebtedness to Community Trust Bank

(now Origin Bank). The collateral outlined in the security agreement was a

2013 King Air 250 B200GT bearing F.A.A. registration number N5087G,

together with its engines, all avionics, log books, attachments, etc. On the

same day Jason Bullock executed and signed the security agreement, Jason

Bullock executed a promissory note (“Note 1”) in favor of Origin Bank in

the original amount of $3,866,199. The terms of Note 1 dictated that the

first payment on the note was due on January 1, 2014, with the final

payment due on December 1, 2018.

On September 3, 2014, K. Paul Bullock (“K. Paul”), a member of JPS

Aero, allegedly signed a commercial guaranty in which he agreed to pay any

and all outstanding debts incurred by JPS Aero “arising from any and all present and future loans…that Borrower individually or collectively…owes

or will owe or incur in favor of Lender.”1

As manager of JPS Aviation and on behalf of JPS Aero, Jason

Bullock executed another promissory note (“Note 2”) in the original amount

of $75,250, on February 10, 2017. This note provided that the first payment

be due on March 10, 2017, with all subsequent payments payable on the

same day of each successive month until paid in full, and that the final

payment be due on February 10, 2022.

On December 31, 2017, K. Paul terminated his ownership of and

membership in JPS Aero and sold these interests to Jason Bullock and

Margaret L. Bullock. K. Paul later notified Origin Bank via letter on August

28, 2018, that he was terminating any outstanding commercial guaranties as

to JPS Aero.

Origin Bank filed suit to collect when JPS Aero failed to make several

payments on Note 1 and Note 2. In its petition, Origin Bank asserted that

the payment due on December 1, 2018, for Note 1 was never made despite

amicable demand. Origin Bank elected to mature Note 1 in its entirety

pursuant to its terms. Furthermore, Origin Bank also asserted that payments

due on January 10, 2020, February 10, 2020, March 10, 2020, and April 10,

2020, for Note 2 were not made. According to the terms of Note 2, Origin

Bank chose to mature Note 2 in its entirety.

Because of its inability to pay on both promissory notes, JPS Aero

confessed judgment for purposes of foreclosure and acknowledged

indebtedness to Origin Bank up to the full amount of indebtedness. As a

1 K. Paul alleges that he does not remember executing this Commercial Guaranty.

2 result, the 2013 King Air 250 was sold at a sheriff’s sale in Ouachita Parish.

The sale of the aircraft resulted in a credit of $1,075,001 being applied to the

amount owed to Origin Bank effective on December 2, 2020.

On July 21, 2021, Origin Bank filed a petition for deficiency

judgment and named as defendants JPS Aero, JPS Aviation, K. Paul, and

Margaret L. Bullock. In the petition, Origin Bank alleged that the

defendants owed $3,382,986.69, less a credit of $1,075,001, as borrowers

and guarantors of the debts incurred by JPS Aero.

Origin Bank filed a motion for partial summary judgment on

November 4, 2021, and included in the motion an affidavit from Bryan

Burgess, an authorized representative of Origin Bank. Prior to the summary

judgment hearing, the trial court sustained K. Paul’s objection to Burgess’

affidavit submitted by Origin Bank for the purpose of “authenticating” the

commercial guaranty allegedly signed by K. Paul. Because it struck the

affidavit, the trial court found that none of the documents attached could be

“authenticated,” including the commercial guaranty allegedly signed by K.

Paul. Because the commercial guaranty could not be “authenticated,” the

trial court decided it was inadmissible evidence in support of Origin Bank’s

motion. Without the commercial guaranty as evidence, the trial court ruled

that Origin Bank could not meet its burden of proof on summary judgment

and denied Origin Bank’s motion for partial summary judgment.

Following the trial court’s denial of Origin Bank’s summary judgment

motion, the bank sought supervisory review, arguing that the trial court erred

in sustaining K. Paul’s objection to the affidavit and in not considering the

evidence submitted in support of the motion for partial summary judgment.

3 This Court granted the application for review and issued the following

findings and directions:

The requirement that affidavits be based on personal knowledge is satisfied when the affiant is qualified to identify business records as such. La. C.C.P. art. 967; Bank of Am., N.A. v. Green, 52,044 (La. App. 2 Cir. 5/23/18), 249 So. 3d 219. So considering, we find that the trial court erred in excluding the affidavit of Bryan Burgess as support for applicant’s motion for partial summary judgment. The trial court’s order sustaining the objection and denying the motion for partial summary judgment is reversed. The matter is remanded for the trial court’s reconsideration of applicant’s motion for partial summary judgment with consideration of Bryan Burgess’ affidavit and attachments as proper summary judgment evidence. See also, Custom-Bilt Cabinet & Supply, Inc. [supra].

After remand, the trial court reheard arguments on Origin Bank’s

motion for partial summary judgment on April 24, 2023. At the rehearing,

Origin Bank argued that K. Paul is liable for payment as a guarantor/surety

for all debts incurred by JPS Aero prior to and during the life of the

commercial guaranty. Origin Bank contended that K. Paul signed a

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Origin Bank v. Aero, L.L.C., JPS Aviation, L.L.C., K. Paul Bullock, and Margaret L. Bullock, Counsel Stack Legal Research, https://law.counselstack.com/opinion/origin-bank-v-aero-llc-jps-aviation-llc-k-paul-bullock-and-lactapp-2024.