Each card carries the governed distillate name from the database. Open the quoted anchor before relying on the interpretation.
quotationattribution
Pennetti acknowledges that the defendants do not have a bond and do not have a Virginia order, despite earlier broader representations in th
Pennetti acknowledges that the defendants do not have a bond and do not have a Virginia order, despite earlier broader representations in the same hearing.
Read the anchor · page 10
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Hearing
October 28, 2024
will stay it. Absent that, I don't think there's
anything else to discuss.
MR. PENNETI: Judge, there is a basis. As
long as we requested the stay under 35.006, the
particular language is that a stay of execution has been
granted, has been requested, or will be requested. So
we don't even have to request it at this point because
we have posted the bond. As long as we have requested
it, which we have, or we would request it and have
posted bond, which we have and we have also granted a
security interest, you still have to stay the action.
So --
THE COURT: You're saying under Virginia
law it's stayed?
MR. PENNETI: No, Judge, what I'm saying
is that under Texas law you're required to stay the
action because we have requested the stay. That's what
35.006 says. I can share my screen with you if you
would like.
THE COURT: Sure.
MR. PENNETI: Okay. The language I'm
referring to is right here.
THE COURT: Right. I mean, so we're
talking about a situation where, you know, you
superseded a judgment and you're putting up the
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claimallegation
The eighteen-page reporter’s record concerns the 28 October 2024 hearing in Harris County cause 2024-48085 before Michael Gomez on defendant
The eighteen-page reporter’s record concerns the 28 October 2024 hearing in Harris County cause 2024-48085 before Michael Gomez on defendants’ motion to vacate/stay the foreign judgment. Shawn Grady appears for plaintiffs and Alex Penneti for defendants, with bar number 24110208. Jennifer Gajevsky certifies the requested proceedings, CSR 9250, expiration printed February 2026. The transcript spelling Penneti is retained as a source variant of counsel’s name.
Read the anchor · page 1
1
Hearing
October 28, 2024
REPORTER'S RECORD
VOLUME 1 OF 1 VOLUMES
TRIAL COURT CAUSE NO. 2024-48085
ATLANTIC WAVE HOLDINGS, ) IN THE DISTRICT COURT
LLC AND SECURE COMMUNITY, )
LLC )
)
vs. ) HARRIS COUNTY, TEXAS
)
CYBERLUX CORPORATION AND )
MARK SCHMIDT, INDIVIDUALLY )
) 129TH JUDICIAL DISTRICT
_____________________________________________
HEARING
_____________________________________________
On the 28th day of October, 2024, the following
proceedings came on to be held in the above-titled
and numbered cause before the Honorable Michael
Gomez, Judge Presiding, held in Houston, Harris
County, Texas.
Proceedings reported by computerized stenotype
machine.
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claimallegation
Pennetti describes the June 2023 settlement, consent judgment, Virginia forum clause and related California/Virginia litigation, referring t
Pennetti describes the June 2023 settlement, consent judgment, Virginia forum clause and related California/Virginia litigation, referring to Strikepoint with varying transcribed names. He characterises the enforcement as a contract dispute and argues later litigation could alter the judgment. Gomez distinguishes enforcing the existing final judgment from revisiting its merits. The transcript proves those positions were stated, not that every described outside proceeding had that posture.
Read the anchor · page 3
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Hearing
October 28, 2024
THE COURT: Court is on the record, Cause
No. 2024-48085.
Will everyone, please, introduce
themselves for the record.
MR. GRADY: Shawn Grady for the Plaintiff.
MR. PENNETI: Alex Penneti for the
Defendants.
THE COURT: One second. I'm trying to --
this is Defendant's Motion to Vacate and Motion to Stay
the foreign judgment; is that right?
MR. PENNETI: That's right.
THE COURT: You may proceed.
MR. PENNETI: Judge, this action was
brought following a settlement agreement entered by the
parties that was entered last summer, so June of 2023,
the settlement agreement was entered in Virginia. I
would like to touch on that before I get into some of
the other issues here. The settlement agreement itself
was entered in June. As a part of that, the parties
included a venue and choice of law provision to dictate
any disputes arising from the settlement agreement will
be litigated in Virginia pursuant to Virginia law.
THE COURT: Can I -- so this is a little
bit confusing but I want to make sure I kind of figure
out where -- what we're talking about because --
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claimallegation
Pennetti says Cyberlux granted a security interest and made $779,000 in payments, and expresses concern about collection of the full approxi
Pennetti says Cyberlux granted a security interest and made $779,000 in payments, and expresses concern about collection of the full approximately $1.5 million. Gomez observes that collection proceeds only until satisfaction and asks about modification, appeal and supersession. No accounting adjudication or payment ledger is supplied in the hearing record.
Read the anchor · page 5
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Hearing
October 28, 2024
do. What essentially happened is my client ended up
granting a security interest in all of its property at
the time of the settlement agreement, so June 2023. It
also, again, began making payments on the settlement.
It made payments from July 3 all the way through
May 31st. And I know there are a couple different
breach theories. The May 31st breach theory is
essentially part of Plaintiff's complaint is we stopped
making payments on the settlement May 31. That's
because in some Virginia litigation -- on a higher
level, Judge -- there are currently, as I understand,
five other proceedings in addition to this one. So
ignoring the specifics of the alleged breach by
Plaintiffs, really what happened is Plaintiffs contend
that we breached the settlement agreement. And so, they
hauled off and instead of filing an action in Virginia,
they hauled off to California state court, filed a suit
there. We removed it to federal court at which time
Plaintiffs filed a second suit in California. That
ended up in federal court, as well. The first
California lawsuits is the same posture. There's a
motion to vacate pending by my client there. Same
posture as here. Second lawsuit was litigated for
several months. My client filed counterclaims in that
action. The Court ultimately looked at the settlement
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claimallegation
Pennetti initially says the Virginia stay has occurred and confirms that enforcement of the domesticated judgment has been stayed. When Gome
Pennetti initially says the Virginia stay has occurred and confirms that enforcement of the domesticated judgment has been stayed. When Gomez asks for the order, he says he has no copy because another firm handles Virginia. Grady disputes that an order exists. At this stage the statements are contested, not a produced Virginia stay.
Read the anchor · page 8
8
Hearing
October 28, 2024
appealed, that's correct. And that was part of the
language of the consent judgment. But part of it is we
sought a stay of execution through injunctive relief
there because we have done that and because we granted
the security interest at minimum, Judge, you have to
stay the action. You have to either vacate it or stay
it here. So while we --
THE COURT: Has it been stayed? I mean
has it been stayed in Virginia?
MR. PENNETI: Those -- all those
litigations, yes, the stay has occurred in Virginia.
There's no -- the collection -- there's no activity in
the collection suit. Then you've got the three other
lawsuits.
THE COURT: So the enforcement of this
judgment that they domesticated has been stayed in
Virginia?
MR. PENNETI: That's correct. And it's
also --
THE COURT: Hold on. Mr. Grady?
MR. GRADY: Yes, Your Honor.
THE COURT: Is that right?
MR. GRADY: -- that shows the Virginia
judgment has been stayed. I know they filed a complaint
for an injunction seeking a stay. According to my
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claimallegation
Pennetti shifts to arguing that a requested stay and security require a Texas stay under section 35.006. After saying a bond has been posted
Pennetti shifts to arguing that a requested stay and security require a Texas stay under section 35.006. After saying a bond has been posted, he answers the court that they do not have a bond and instead granted a security interest. On page 13 he expressly says they do not have an order and describes pending requests. Gomez rejects an automatic stay based solely on filing something and asks about a genuinely pursued, secured proceeding.
Read the anchor · page 10
10
Hearing
October 28, 2024
will stay it. Absent that, I don't think there's
anything else to discuss.
MR. PENNETI: Judge, there is a basis. As
long as we requested the stay under 35.006, the
particular language is that a stay of execution has been
granted, has been requested, or will be requested. So
we don't even have to request it at this point because
we have posted the bond. As long as we have requested
it, which we have, or we would request it and have
posted bond, which we have and we have also granted a
security interest, you still have to stay the action.
So --
THE COURT: You're saying under Virginia
law it's stayed?
MR. PENNETI: No, Judge, what I'm saying
is that under Texas law you're required to stay the
action because we have requested the stay. That's what
35.006 says. I can share my screen with you if you
would like.
THE COURT: Sure.
MR. PENNETI: Okay. The language I'm
referring to is right here.
THE COURT: Right. I mean, so we're
talking about a situation where, you know, you
superseded a judgment and you're putting up the
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claimallegation
Gomez says he would consider a short bridge where the Virginia matter is actually being pursued with security and an imminent hearing, but w
Gomez says he would consider a short bridge where the Virginia matter is actually being pursued with security and an imminent hearing, but will not halt enforcement merely because a request is on file. Pennetti says he is not involved in the Virginia matter and has only some knowledge of it. This provisional discussion is not the hearing’s final disposition.
Read the anchor · page 13
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Hearing
October 28, 2024
when the judgment itself is subject to the modification.
That's precisely the situation with this judgment
because of the Virginia litigation that's pending. And
so, it's really the statute.
THE COURT: So here's -- so what exactly
do you have the Virginia court vis-a-vis the stay?
MR. PENNETI: I think we have got four
active lawsuits. I think our requests are pending and
that's in terms of Your Honor's request for an order.
We do not have an order.
THE COURT: When you say it's pending,
what does that mean?
MR. PENNETI: Our actions' been filed.
Frankly, we filed request for injunctive relief and
declaratory relief.
THE COURT: So here's -- so let's assume
for a moment that I'm willing to go on this -- follow
this line of logic. I don't believe that this is, in
essence, a self executing stay where you can file
something and say, hey, it's pending and I'm not going
to do anything with it. If you, in fact, have something
that you are actually prosecuting, that you have pending
before a Judge, that's been heard, that you filed the --
furnished the security to satisfy the judgment required
in the state. You have done all of those things, then,
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claimallegation
Grady says current activity is depositions/discovery, with no writs requested or actual enforcement action yet. He identifies possible wareh
Grady says current activity is depositions/discovery, with no writs requested or actual enforcement action yet. He identifies possible warehouse drones, contracts and receivables but says their existence is not yet known. Gomez declines to stay discovery and initially suggests a two-week enforcement stay. These statements are specific to the October hearing, not all later collection activity.
Read the anchor · page 15
15
Hearing
October 28, 2024
THE COURT: So Mr. Grady -- here's -- are
you doing anything in terms of collection right now?
MR. GRADY: Your Honor, the only thing
we're seeking to do is take the deposition of a couple
of witnesses. We noticed them. They were quashed and
nothing else. That's it.
THE COURT: But you haven't sought to
execute on it? I don't know if they have anything. Or
you may not know.
MR. GRADY: We haven't requested any writs
or taken an actual enforcement action. Just discovery.
THE COURT: So Mr. Penneti, is there
something you're concerned about besides some
depositions?
MR. PENNETI: Judge, other than the
depositions and discovery, all we have here is we have a
lease here with some property on it. Again, that goes
back to the notion that all this needs to be litigated
in Virginia where all the parties and concerns are and
really -- but, no, other than that I don't have concerns
other than the fact that -- I'm concerned with
inconsistent outcome with three different ongoing
litigations. Irrespective of my clients litigation, the
litigation brought by Defendants, if that were the
result, unfavorably, for them and modified the
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claimallegation
The final exchange changes the proposed two weeks to thirty days at Pennetti’s request, with Grady’s agreement. Gomez expressly stays enforc
The final exchange changes the proposed two weeks to thirty days at Pennetti’s request, with Grady’s agreement. Gomez expressly stays enforcement for thirty days, excludes discovery and permits supplementation and a further hearing/submission if continued relief is sought. He says the stay expires after thirty days. This is an actual oral ruling recorded in the transcript, not merely a requested stay or an outright failure to obtain relief.
Read the anchor · page 16
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Hearing
October 28, 2024
settlement agreement, again, allowing collection at this
stage would be inconsistent and that's why this is not
at final judgment but interlocutory.
THE COURT: Okay. So -- if all they're
doing right now is just discovery then I don't think
there's any real -- I'm not going to stay the discovery.
If they were doing some enforcement I would be -- and
you were trying to prosecute this other stuff in
Virginia, I could say, hey, let's hold on a minute
before you, you know, sell something or garnish
something or sequester something. That might have a
more -- there might be more urgency there. So this
is -- so why don't we do this. Mr. Grady, is the fact
that you're not enforcing because you're not aware of
any assets?
MR. GRADY: Well, they have a warehouse
which they're leasing. They may have drones stored
there. They manufacture drones. And so, there might be
assets in Texas but we don't know for sure. And so, or
contracts and receivables, things like that that could
be recovered but we're not aware. That's why we're
doing the discovery, of course.
THE COURT: Tell you what. If you want,
you can -- I will go ahead and stay enforcement for two
weeks but not any discovery. I'm not going to stay any
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claimallegation
The reporter’s certification covers the requested portions included in the volume and bears an /s/ signature. The transcript does not attach
The reporter’s certification covers the requested portions included in the volume and bears an /s/ signature. The transcript does not attach a later written order, Virginia stay, bond, supplemental filing or extension. Its recorded thirty-day Texas enforcement stay does not establish a Virginia stay or indefinite bar on discovery.
Read the anchor · page 18
18
Hearing
October 28, 2024
STATE OF TEXAS
COUNTY OF HARRIS
I, Jennifer Gajevsky, Official Court Reporter in and
for the 129th District Court of Harris, State of
Texas, do hereby certify that the above and
foregoing contains a true and correct transcription
of all portions of evidence and other proceedings
requested in writing by counsel for the parties to
be included in this volume of the Reporter's Record
in the above-styled and numbered cause, all of which
occurred in open court or in chambers and were
reported by me.
I further certify that this Reporter's Record of the
proceedings truly and correctly reflects the
exhibits, if any, offered by the respective parties.
/s/ Jennifer Gajevsky
Jennifer Gajevsky, CSR
Texas CSR 9250
Official Court Reporter
129th District Court
Harris County, Texas
201 Caroline
Houston, Texas 77002
Expiration: 2/2026
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entityobservation
Michael
Read the anchor · page 1
1
Hearing
October 28, 2024
REPORTER'S RECORD
VOLUME 1 OF 1 VOLUMES
TRIAL COURT CAUSE NO. 2024-48085
ATLANTIC WAVE HOLDINGS, ) IN THE DISTRICT COURT
LLC AND SECURE COMMUNITY, )
LLC )
)
vs. ) HARRIS COUNTY, TEXAS
)
CYBERLUX CORPORATION AND )
MARK SCHMIDT, INDIVIDUALLY )
) 129TH JUDICIAL DISTRICT
_____________________________________________
HEARING
_____________________________________________
On the 28th day of October, 2024, the following
proceedings came on to be held in the above-titled
and numbered cause before the Honorable Michael
Gomez, Judge Presiding, held in Houston, Harris
County, Texas.
Proceedings reported by computerized stenotype
machine.
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entityobservation
Shawn Grady
Read the anchor · page 2
2
Hearing
October 28, 2024
APPEARANCES
Mr. Shawn Grady
SBOT NO. 24076411
LAW FIRM OF SHAWN M. GRADY, PLLC
2100 West Loop South
Houston, Texas 77027
Counsel for Plaintiff
Mr. Alex Penneti
SBOT NO. 24110208
THOMPSON COBURN LLP
2100 Ross Avenue
Dallas, Texas 75201
Counsel for Defendants
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entityobservation
Alex Penneti
Read the anchor · page 2
2
Hearing
October 28, 2024
APPEARANCES
Mr. Shawn Grady
SBOT NO. 24076411
LAW FIRM OF SHAWN M. GRADY, PLLC
2100 West Loop South
Houston, Texas 77027
Counsel for Plaintiff
Mr. Alex Penneti
SBOT NO. 24110208
THOMPSON COBURN LLP
2100 Ross Avenue
Dallas, Texas 75201
Counsel for Defendants
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entityobservation
Jennifer Gajevsky
Read the anchor · page 18
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Hearing
October 28, 2024
STATE OF TEXAS
COUNTY OF HARRIS
I, Jennifer Gajevsky, Official Court Reporter in and
for the 129th District Court of Harris, State of
Texas, do hereby certify that the above and
foregoing contains a true and correct transcription
of all portions of evidence and other proceedings
requested in writing by counsel for the parties to
be included in this volume of the Reporter's Record
in the above-styled and numbered cause, all of which
occurred in open court or in chambers and were
reported by me.
I further certify that this Reporter's Record of the
proceedings truly and correctly reflects the
exhibits, if any, offered by the respective parties.
/s/ Jennifer Gajevsky
Jennifer Gajevsky, CSR
Texas CSR 9250
Official Court Reporter
129th District Court
Harris County, Texas
201 Caroline
Houston, Texas 77002
Expiration: 2/2026
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eventattribution
Gomez heard the motion and granted the limited thirty-day enforcement stay.
Read the anchor · page 1
1
Hearing
October 28, 2024
REPORTER'S RECORD
VOLUME 1 OF 1 VOLUMES
TRIAL COURT CAUSE NO. 2024-48085
ATLANTIC WAVE HOLDINGS, ) IN THE DISTRICT COURT
LLC AND SECURE COMMUNITY, )
LLC )
)
vs. ) HARRIS COUNTY, TEXAS
)
CYBERLUX CORPORATION AND )
MARK SCHMIDT, INDIVIDUALLY )
) 129TH JUDICIAL DISTRICT
_____________________________________________
HEARING
_____________________________________________
On the 28th day of October, 2024, the following
proceedings came on to be held in the above-titled
and numbered cause before the Honorable Michael
Gomez, Judge Presiding, held in Houston, Harris
County, Texas.
Proceedings reported by computerized stenotype
machine.
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inferenceinference
The full sequence narrows and partly withdraws the initial definitive representations: counsel ultimately says there is no order and no bond
The full sequence narrows and partly withdraws the initial definitive representations: counsel ultimately says there is no order and no bond. That establishes an internal change in the account, not by itself a finding of deliberate dishonesty.
inferenceinference
The final thirty-day enforcement stay controls the hearing outcome. Quoting the court’s earlier reluctance without the closing ruling would
The final thirty-day enforcement stay controls the hearing outcome. Quoting the court’s earlier reluctance without the closing ruling would misdescribe the result; discovery nevertheless remained permitted.
otherattribution
Complete supplied 18-page source reviewed at SHA-256 151da1d6dbf728d58c6850a3764f292d4962ad770f9e2ee24dd5709b77502868. Source assertions, or
Complete supplied 18-page source reviewed at SHA-256 151da1d6dbf728d58c6850a3764f292d4962ad770f9e2ee24dd5709b77502868. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. No unexamined later court outcome is inferred.
Read the anchor · page 1
1
Hearing
October 28, 2024
REPORTER'S RECORD
VOLUME 1 OF 1 VOLUMES
TRIAL COURT CAUSE NO. 2024-48085
ATLANTIC WAVE HOLDINGS, ) IN THE DISTRICT COURT
LLC AND SECURE COMMUNITY, )
LLC )
)
vs. ) HARRIS COUNTY, TEXAS
)
CYBERLUX CORPORATION AND )
MARK SCHMIDT, INDIVIDUALLY )
) 129TH JUDICIAL DISTRICT
_____________________________________________
HEARING
_____________________________________________
On the 28th day of October, 2024, the following
proceedings came on to be held in the above-titled
and numbered cause before the Honorable Michael
Gomez, Judge Presiding, held in Houston, Harris
County, Texas.
Proceedings reported by computerized stenotype
machine.
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questionquestion
What entered written order, later supplement and Virginia docket records show implementation, extension and the actual status of the asserte
What entered written order, later supplement and Virginia docket records show implementation, extension and the actual status of the asserted Virginia requests?
allegation
CONNECT
Reviewed relationships
The canvas follows the database: source to DISTIL record, DISTIL record to knowledge object, then reviewed relationship. Position alone means nothing.
Welter alleges asset-sale attempts, dilatory Virginia suits filed 8 July 2024 and loss of judgment collateral, relying on separate Zablah and docket materials. He says he attended the 28 October Texas hearing telephonically and claims a false Virginia-stay statement misled the court into a thirty-day execution stay while discovery continued. This includes an express acknowledgement of the limited stay; his causal/motive account remains an allegation requiring the full transcript.referencesPennetti shifts to arguing that a requested stay and security require a Texas stay under section 35.006. After saying a bond has been posted, he answers the court that they do not have a bond and instead granted a security interest. On page 13 he expressly says they do not have an order and describes pending requests. Gomez rejects an automatic stay based solely on filing something and asks about a genuinely pursued, secured proceeding.
The full transcript records counsel’s acknowledgement of no bond and no order before relief; that clarification must accompany the allegation that the judge was misled.
The motion says prior emergency stay attempts all failed and specifically says Pennetti failed to persuade Gomez on October 28, 2024, quoting page 14 of that transcript. It also describes the separate $9,392.50 Virginia fee award as arising from a similar emergency motion and alleges non-payment. The partial hearing quotation does not include that transcript’s final ruling; the actual full transcript is a separate controlling dependency.referencesThe final exchange changes the proposed two weeks to thirty days at Pennetti’s request, with Grady’s agreement. Gomez expressly stays enforcement for thirty days, excludes discovery and permits supplementation and a further hearing/submission if continued relief is sought. He says the stay expires after thirty days. This is an actual oral ruling recorded in the transcript, not merely a requested stay or an outright failure to obtain relief.
The receiver says the October attempt failed, but final transcript page 17 records a thirty-day enforcement stay, excluding discovery. Final disposition controls description of the hearing result.
He quotes Pennetti’s October assertion that enforcement was stayed in Virginia, characterises it as untruthful and asks $7,500 sanctions jointly and severally against Pennetti/Thompson Coburn, payable directly to him within ten days of an order. He also seeks a requirement for prior written Gomez permission before any emergency motion, denial of stay and continuation of receivership. These are requested remedies, not existing sanctions or filing restrictions.referencesPennetti initially says the Virginia stay has occurred and confirms that enforcement of the domesticated judgment has been stayed. When Gomez asks for the order, he says he has no copy because another firm handles Virginia. Grady disputes that an order exists. At this stage the statements are contested, not a produced Virginia stay.
The sanctions motion repeats the initial Virginia-stay assertion; full hearing context includes later qualification and a separate Texas ruling.
Pennetti initially says the Virginia stay has occurred and confirms that enforcement of the domesticated judgment has been stayed. When Gomez asks for the order, he says he has no copy because another firm handles Virginia. Grady disputes that an order exists. At this stage the statements are contested, not a produced Virginia stay.supportsWhat entered written order, later supplement and Virginia docket records show implementation, extension and the actual status of the asserted Virginia requests?
Specifically named source propositions support the bounded distinction or question.
The final exchange changes the proposed two weeks to thirty days at Pennetti’s request, with Grady’s agreement. Gomez expressly stays enforcement for thirty days, excludes discovery and permits supplementation and a further hearing/submission if continued relief is sought. He says the stay expires after thirty days. This is an actual oral ruling recorded in the transcript, not merely a requested stay or an outright failure to obtain relief.supportsWhat entered written order, later supplement and Virginia docket records show implementation, extension and the actual status of the asserted Virginia requests?
Specifically named source propositions support the bounded distinction or question.
Pennetti shifts to arguing that a requested stay and security require a Texas stay under section 35.006. After saying a bond has been posted, he answers the court that they do not have a bond and instead granted a security interest. On page 13 he expressly says they do not have an order and describes pending requests. Gomez rejects an automatic stay based solely on filing something and asks about a genuinely pursued, secured proceeding.supportsThe full sequence narrows and partly withdraws the initial definitive representations: counsel ultimately says there is no order and no bond. That establishes an internal change in the account, not by itself a finding of deliberate dishonesty.
Specifically named source propositions support the bounded distinction or question.
Grady says current activity is depositions/discovery, with no writs requested or actual enforcement action yet. He identifies possible warehouse drones, contracts and receivables but says their existence is not yet known. Gomez declines to stay discovery and initially suggests a two-week enforcement stay. These statements are specific to the October hearing, not all later collection activity.supportsThe final thirty-day enforcement stay controls the hearing outcome. Quoting the court’s earlier reluctance without the closing ruling would misdescribe the result; discovery nevertheless remained permitted.
Specifically named source propositions support the bounded distinction or question.
The reporter’s certification covers the requested portions included in the volume and bears an /s/ signature. The transcript does not attach a later written order, Virginia stay, bond, supplemental filing or extension. Its recorded thirty-day Texas enforcement stay does not establish a Virginia stay or indefinite bar on discovery.supportsWhat entered written order, later supplement and Virginia docket records show implementation, extension and the actual status of the asserted Virginia requests?
Specifically named source propositions support the bounded distinction or question.
Gomez says he would consider a short bridge where the Virginia matter is actually being pursued with security and an imminent hearing, but will not halt enforcement merely because a request is on file. Pennetti says he is not involved in the Virginia matter and has only some knowledge of it. This provisional discussion is not the hearing’s final disposition.supportsThe full sequence narrows and partly withdraws the initial definitive representations: counsel ultimately says there is no order and no bond. That establishes an internal change in the account, not by itself a finding of deliberate dishonesty.
Specifically named source propositions support the bounded distinction or question.
Pennetti initially says the Virginia stay has occurred and confirms that enforcement of the domesticated judgment has been stayed. When Gomez asks for the order, he says he has no copy because another firm handles Virginia. Grady disputes that an order exists. At this stage the statements are contested, not a produced Virginia stay.supportsThe full sequence narrows and partly withdraws the initial definitive representations: counsel ultimately says there is no order and no bond. That establishes an internal change in the account, not by itself a finding of deliberate dishonesty.
Specifically named source propositions support the bounded distinction or question.
Pennetti shifts to arguing that a requested stay and security require a Texas stay under section 35.006. After saying a bond has been posted, he answers the court that they do not have a bond and instead granted a security interest. On page 13 he expressly says they do not have an order and describes pending requests. Gomez rejects an automatic stay based solely on filing something and asks about a genuinely pursued, secured proceeding.supportsWhat entered written order, later supplement and Virginia docket records show implementation, extension and the actual status of the asserted Virginia requests?
Specifically named source propositions support the bounded distinction or question.
The final exchange changes the proposed two weeks to thirty days at Pennetti’s request, with Grady’s agreement. Gomez expressly stays enforcement for thirty days, excludes discovery and permits supplementation and a further hearing/submission if continued relief is sought. He says the stay expires after thirty days. This is an actual oral ruling recorded in the transcript, not merely a requested stay or an outright failure to obtain relief.supportsThe final thirty-day enforcement stay controls the hearing outcome. Quoting the court’s earlier reluctance without the closing ruling would misdescribe the result; discovery nevertheless remained permitted.
Specifically named source propositions support the bounded distinction or question.
Gomez says he would consider a short bridge where the Virginia matter is actually being pursued with security and an imminent hearing, but will not halt enforcement merely because a request is on file. Pennetti says he is not involved in the Virginia matter and has only some knowledge of it. This provisional discussion is not the hearing’s final disposition.supportsThe final thirty-day enforcement stay controls the hearing outcome. Quoting the court’s earlier reluctance without the closing ruling would misdescribe the result; discovery nevertheless remained permitted.
Specifically named source propositions support the bounded distinction or question.
The final exchange changes the proposed two weeks to thirty days at Pennetti’s request, with Grady’s agreement. Gomez expressly stays enforcement for thirty days, excludes discovery and permits supplementation and a further hearing/submission if continued relief is sought. He says the stay expires after thirty days. This is an actual oral ruling recorded in the transcript, not merely a requested stay or an outright failure to obtain relief.supportsDid Gomez refuse all stay relief at this hearing?
Specifically named source propositions support the bounded distinction or question.
WEIGH
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