Steadfast 829 Holdings, Inc. v. Choudhri

District Court, S.D. Texas·Decided March 12, 2025·No. 4:22-cv-00905·Unknown

Opinion

□ Southern District of Texas ENTERED March 13, 2025 IN THE UNITED STATES DISTRICT COURT Nathan Ochsner, Clerk FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION STEADFAST 829 HOLDINGS, INC., § § Plaintiff; § § Vv. § CIVIL ACTION NO. H-22-0905 § 2017 YALE DEVELOPMENT, LLC, = § et al., § § Defendants. § MEMORANDUM OPINION AND ORDER The Court informed counsel and the litigants earlier in this case that the issues of sanctions and lawsuit preclusion would best be considered toward the end of the lawsuit, not at its commencement. This case has reached its end-point. The Court has taken a careful look in the rear-view mirror to assess the damage and detritus, and finds the path littered with potentially sanctionable actions by any number of parties and counsel. Pending before the Court are the following motions: Motions for “Injunctive Relief to Prevent Ramey and his Steadfast Clients from Vexatiously Filing Lawsuits Against Defendants,” filed by movant Norma Lopez (Docket Entry No. 31), movant Donald Huebner (Docket Entry No. 32), and movant Carb Pura Vida, LLC (Docket Entry No. 33); and “Motion to Identify Christopher Ramey, Marc Sherrin, and Steadfast Funding, LLC, as Vexatious Litigants and Entry of Anti-Suit Injunction,” filed by movants Nicholas Fugedi (Individually and as Trustee), Michelle Fraga, and Fraga Law

Office, PLLC (Docket Entry No. 43) (collectively the “Pre-Filing Injunction Motions”); along with various joinders, responses, replies, and sur-replies; “Motion for Sanctions,” filed by movant Lloyd E. Kelley (Docket Entry No. 74), along with various responses; and “Motion for Sanctions,” filed by movant Donald Huebner (Docket Entry No. 103); and The Amended Motion (Docket Entry No. 516) and Supplemental Motion (Docket Entry No. 542) for a show cause hearing, dismissal of the pending lawsuit in C.A. No. H-24- 0404 (S.D. Tex.), sanctions, and to “refer the matter to the United States Attorney for investigation,” filed by movants Michelle Fraga, Nicholas Fugedi, Carb Pura Vida Trust, Lloyd E. Kelley, and Pabeshan Castle (the “Motions to Show Cause”), along with various joinders and responses. Having considered the pending motions, the responses, the replies, the sur-replies, the record, matters of public record, and the applicable law, the Court LIFTS THE STAY as to Docket Entries No. 31, 32, 33, 43, 74, and 103; STRIKES the amended motion and supplemental motion to show cause (Docket Entries No. 512, 516, 542), and DENIES the motions (Docket Entries No. 31, 32, 33, 43, 74, 103) for the reasons shown below. II. ANALYSIS A. Pre-Filing Injunction In their Pre-Filing Injunction Motions (Docket Entries No. 31, 32, 33, 43), movants

argue that “Ramey and his Steadfast Clients” are vexatious litigants, and that the Court

should impose a permanent injunction preventing them from filing new lawsuits against the

movants without prior authorization of this Court.' In support, movants argue that “the fact that Mr. Ramey has filed four previous lawsuits and filed counter-claims in two other lawsuits over the same property weighs in favor of an order preventing him and his clients

from filing any more such suits without first getting permission of this Court.” (Docket Entry No. 31, § 29.) Movants further complain that Ramey and his Steadfast Clients filed, and continue to file, intentionally false lawsuits and counter-claims against them, repeatedly seeking relief that has been denied by other state and federal courts. A federal district court has jurisdiction to impose a pre-filing injunction to deter vexatious, abusive, and harassing litigation in federal courts. Farguson v. MBank Houston, N.A., 808 F.2d 358, 360 (5th Cir. 1986) (recognizing the district court’s inherent power to

protect its jurisdiction and judgments and to control its own dockets); Day v. Allstate Ins. Co., 788 F.2d 1110, 1115 (5th Cir. 1986) (holding that a district court may impose a pre-filing injunction, which would bar a litigant from filing any additional actions without first obtaining leave from the district court, to deter vexatious filings) (citing Martin—Trigona

v, Lavien, 737 F.2d 1254, 1261-62 (2d Cir. 1984)). A pre-filing injunction “must be tailored

to protect the courts and innocent parties, while preserving the legitimate rights of litigants.” Farguson, 808 F.2d at 360. A district court’s decision to grant an injunction is reviewed

'The motions essentially present the same facts and grounds for pre-filing injunctive relief. The Court will refer to Docket Entry No. 31 as the representative motion for convenience and efficiency.

under the abuse of discretion standard. Newby v. Enron Corp., 302 F.3d 295, 301 (Sth Cir. 2002). In determining whether a pre-filing injunction should be imposed to deter vexatious filings, a court must weigh all the relevant circumstances, including the following four factors: (1) the party’s history of litigation, in particular whether it has filed vexatious, harassing, or duplicative lawsuits; (2) whether the party had a good faith basis for pursuing the litigation, or simply intended to harass; (3) the extent of the burden on the courts and other parties resulting from the party’s filings; and (4) the adequacy of alternative sanctions. Baum y. Blue Moon Ventures, 513 F.3d 181, 187 (5th Cir. 2008) (citing Cromer v. Kraft Foods N. Am., Inc., 390 F.3d 812, 818 (4th Cir. 2004)). The United States Court of Appeals for the Fifth Circuit recognizes that “the traditional standards for injunctive relief, ie. irreparable injury and inadequate remedy at law, do not apply to the issuance of an injunction against a vexatious litigant.” Blue Moon, 513 F.3d at 189, citing Martin—Trigona, 737 F.2d

at 1262. In abating the pending motions for a later determination, the Court informed the parties that it would review the record and the parties’ status in light of events that would unfold during the lawsuit’s progression. The Court has undertaken such review, and reiterates observations made in earlier orders that the parties in this case have a long, convoluted, and contentious history that began in 2017 with the purchase and financing of the property at 829 Yale Street in Harris County, Texas. The parties’ ensuing disputes have

been litigated in numerous state and federal lawsuits and appeals, and continue into the

present. Much has happened over the course of this lawsuit, both in this case and in other cases involving the parties. As a result of these and related matters of record, it appeared to the Court that certain pleadings filed by various parties were arguably nonmeritorious. At a

status conference held March 6, 2024, the Court advised the parties that I need to do more analysis of this case, and I will, but the way the pleadings stand right now, I think this is a case for sanctions. I’ll give all the parties and lawyers two weeks, until March 20, 2024, to withdraw pleadings, dismiss adversaries, cancel discovery requests that are nonmeritorious. After that, sanctions will issue. After that, I’m ready to decide the case against all parties and against all lawyers. (Docket Entry No. 498, p. 54.) The Court did not direct its ruling to any particular party or parties, and provided all of the parties a “safe harbor” opportunity to voluntarily withdraw

or dismiss pleadings without the Court’s consideration or imposition of sanctions.

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Related

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808 F.2d 358 (Fifth Circuit, 1986)
Martin-Trigona v. Lavien
737 F.2d 1254 (Second Circuit, 1984)