202283618
JACKSON, AJAYE D vs. LBC2 TRUST
(Court 157, JUDGE TANYA GARRISON)
DEC 28, 2022 | REPUBLISHED BY LIT: DEC 29, 2022
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Ajaye D. Jackson, Plaintiff, in the above entitled and numbered cause and pursuant to Texas Rule of Civil Procedure 162 hereby files this Notice of Nonsuit Without Prejudice as to all of his claims against Defendant LBC2 Trust.
Plaintiff no longer desires to prosecute his claims against the Defendant at this time.
All court costs incurred by the parties shall be the responsibility of the party incurring same except as otherwise specifically ordered by the Court.
Respectfully submitted,
Manfred Sternberg & Associates, P.C.
Manfred Sternberg
SBN: 19175775
1700 Post Oak Blvd. Suite 600
Houston, TX 77056
Telephone: (713) 622-4300
Facsimile: (713) 622-9899
Email: manfred@msternberg.com
COUNSEL FOR PLAINTIFF
CERTIFICATE OF SERVICE
I hereby certify that I have caused a true and correct copy of the above foregoing document to be served upon all lawyers for all parties to this lawsuit in accordance with Rule 21a of the Texas Rules of Civil Procedure electronically by transmission to an electronic filing service provider for service through the state’s electronic filing manager, email, and/or facsimile on this 20th day of
February, 2023.
Manfred Sternberg
Jan 19, Jan 30, Feb 10, 2023
We’re not seein’ any order approving the initial TRO and it’s all very quiet e.g. the plaintiff hasn’t come back with any evidence or answers, even a general denial, so far. Defendants answered the day after suit was filed, and now it’s percolatin’. Bookmark for future updates.
This is the first time Manfred Sternberg has popped up on LIT, but we know the other attorney, Dana Kirkpatrick, a known creditor rights lawyer.
A quick review shows Jackson was President of now defunct Sivco, Inc (commenced business in 1965). He’s now gainfully employed with FGH Insulation Co.
Apparently, there was a personal guarantee of $1.6M for loan(s) to Sivco and now the bank wants it’s money and is seeking to foreclosure on the homestead of the former President. Whether Jackson’s maintained his mortgage payments is unclear from the petition.
We assume he is delinquent and that’s most likely what triggered the foreclosure, as the lawyer would be shoutin’ from the rafters about that if he had caught up with any missed payments or similar.
That stated, foreclosure defense lawyer Sternberg files this complaint to stop the foreclosure auction without even tryin’ to offer any evidence or comply with Texas laws.
For example, there’s no notice to Trustee and an insufficient declaration from Jackson. No evidence at all, just a hey, the title’s clouded and we’re contesting the chain of assignment.
LIT anticipates the TRO will be granted despite the lack of evidence nor compliance.
Bookmark for updates.
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