Acceleration

Sanctioned Lawyer Crystal Gibson of BDF Provides Bennett With A Reason to Stay the Foreclosure Case

Crystal Gibson of BDF requests the Court stay deadlines, docket call and bench trial pending a ruling on Cenlar’s Motion for Summary Judgment.

Hicks v. Cenlar FSB

Yeah, lets get off the forged affidavit submitted with a photocopied signature by BDF’s sanctioned attorney. We can do so by requesting an indefinite stay. “Fabulous idea, it’s Granted”, sayeth Al Bennett.

(4:20-cv-01661)
District Court, S.D. Texas

SEP 21/22, 2021 | REPUBLISHED BY LIT: AUG 27, 2021

DEFENDANT’S MOTION TO STAY PRETRIAL ORDER DEADLINE, DOCKET CALL AND TRIAL DATE

 

TO THE HONORABLE JUDGE OF SAID COURT:

NOW COMES, Defendant Cenlar, FSB (“Defendant”), its successors in interest or assigns, and files this Motion to Stay Pretrial Order Deadline, Docket Call and Trial Date per the court’s Amended Scheduling Order signed February 18, 2021. [Doc. 16]. In support thereof, Defendant would respectfully show the Court:

On March 2, 2020, Plaintiff Jeanie Hicks (“Plaintiff”) sued Defendant to stop foreclosure alleging violations of violations of the Texas Property Code, Texas Business & Commerce Code and Texas Finance Code. Plaintiff also seeks a declaratory judgment and injunctive Defendant filed its answer and affirmative defenses in the State Court proceeding on May 12, 2020 prior to removing the case to this Court. Defendant filed its counterclaim seeking an order allowing foreclosure on June 16, 2020 [Doc. 6].

Plaintiff did not appear at the Court ordered status conference held on July 16, [Doc. 24].

Defendant filed its Motion for Summary Judgment and Brief in Support on July 28, 2021 [Doc. 25]. Plaintiff has not yet filed a response to Defendant’s summary judgment motion.

The current scheduling order signed February 18, 2021 [Doc. 16] sets forth a deadline to file a joint pretrial order on October 4, 2021, a docket call on October 8, 2021, and a trial at 9:00 a.m. on October 11, 2021.

Defendant requests the Court stay the joint pretrial order deadline, docket call and bench trial pending a ruling on Defendant’s Motion for Summary Judgment.

This request for continuance is not for delay only, but so that justice may be done.

WHEREFORE, PREMISES CONSIDERED Defendant requests that this Court stay the joint pretrial order deadline set for October 4, 2021, the docket call set for October 8, 2021, and bench trial set October 11, 2021 until such time as the Court has an opportunity to review and rule on Defendant’s Motion for Summary Judgment.

Respectfully submitted,

By:      /s/ Crystal G. Gibson             

Crystal G. Gibson
State Bar No. 24027322
BARRETT DAFFIN FRAPPIER TURNER & ENGEL, LLP
4004 Belt Line Road, Ste. 100
Addison, Texas 75001
(972) 340-7901
(972) 341-0734 (Facsimile)
CrystalR@bdfgroup.com

ATTORNEYS FOR DEFENDANT

CERTIFICATE OF SERVICE

Pursuant to Texas Rules of Civil Procedure, I certify that a true and correct copy of the foregoing has been sent on this the 21st day of September, 2021 to all parties of record the method indicated below.

VIA E-SERVICE: JHICKS4403@GMAIL.COM

Jeanie Hicks
4403 Ebbtide Drive
Houston, Texas 77045

 

/s/Crystal G. Gibson                                 

Crystal G. Gibson

LIT’s Foreclosure Tracker is Now Following ‘Rosalee’ and BDF in W.D. Tex., San Antonio

It’s Gannon the Cannon firing against the known foreclosure mill and sanctioned lawyer, Crystal Gee Gibson (nee Roach) of BDF Law Group.

LIT Cannot Obtain the Order Re BDF Attorney Fees Dated 24 Sep. 2021 from Pacer And That’s Concerning

So what we have here is the court missed the fact that sanctioned lawyer Gibson did not provide a declaration affidavit for fees.

Medina v The Foreclosure Mill Trio of Mark Hopkins, Shelley Hopkins and Crystal Gibson Settles

When you find Crystal Gee Gibson, the duo of Mark Hopkins and Shelley Hopkins won’t be far behind prepping all the court motions for her.

U.S. District Court
SOUTHERN DISTRICT OF TEXAS (Houston)
CIVIL DOCKET FOR CASE #: 4:20-cv-01661

Create an Alert for This Case on RECAP

Hicks v. Cenlar FSB
Assigned to: Judge Alfred H Bennett

Case in other court:  190th District of Harris County, 20-13548

Cause: 28:1441 Notice of Removal

Date Filed: 05/12/2020
Jury Demand: None
Nature of Suit: 220 Real Property: Foreclosure
Jurisdiction: Diversity
Plaintiff
Jeanie Hicks represented by Jeanie Hicks
4403 Ebbtide Drive
Houston, TX 77045
832-293-5861
PRO SE
V.
Defendant
Cenlar FSB represented by Shelley L. Hopkins
Hopkins Law, PLLC
3 Lakeway Centre Ct.
Suite 110
Austin, TX 78734
512-600-4320
Email: shelley@hopkinslawtexas.com
ATTORNEY TO BE NOTICEDCrystal G Gibson
Barrett Daffin et al
4004 Belt Line Road
Ste 100
Addison, TX 75001
972-340-7901
Email: crystalr@bdfgroup.com
ATTORNEY TO BE NOTICED
Counter Claimant
Cenlar FSB represented by Crystal G Gibson
(See above for address)
ATTORNEY TO BE NOTICED
V.
Counter Defendant
Jeanie Hicks

 

Date Filed # Docket Text
05/12/2020 1 NOTICE OF REMOVAL from 190th District of Harris County, case number 2020-13548 (Filing fee $ 400 receipt number 0541-24653828) filed by Cenlar FSB. (Attachments: # 1 Civil Cover Sheet, # 2 Exhibit A-State Court Pleadings, # 3 Exhibit B-Notice to State Court of Removal, # 4 Exhibit C-List of All Counsel, # 5 Exhibit D-Harris Co. CAD)(Gibson, Crystal) (Entered: 05/12/2020)
05/12/2020 2 First CORPORATE DISCLOSURE STATEMENT by Cenlar FSB, filed.(Gibson, Crystal) (Entered: 05/12/2020)
05/12/2020 3 NOTICE OF SERVICE of Mandatory Initial Discovery Responses by Cenlar FSB, filed. (Gibson, Crystal) (Entered: 05/12/2020)
05/13/2020 4 ORDER for Initial Pretrial and Scheduling Conference and Order to Disclose Interested Persons. Initial Conference set for 8/14/2020 at 09:30 AM in Courtroom 8C before Judge Alfred H Bennett. (Signed by Judge Alfred H Bennett) Parties notified.(ChristopherSarratadi, 4) (Entered: 05/13/2020)
05/13/2020 5 NOTICE to Pro Se Litigant of Case Opening. Party notified, filed. (ChristopherSarratadi, 4) (Entered: 05/13/2020)
06/16/2020 6 ANSWER to 1 State Court Petition/Notice of Removal, COUNTERCLAIM against Jeanie Hicks by Cenlar FSB, filed. (Attachments: # 1 Exhibit A-Note, # 2 Exhibit B-Deed of Trust, # 3 Exhibit C-Assignment, # 4 Exhibit D-Notice of Default)(Gibson, Crystal) (Entered: 06/16/2020)
08/05/2020 7 JOINT DISCOVERY/CASE MANAGEMENT PLAN by Cenlar FSB, filed. (Attachments: # 1 Proposed Order)(Gibson, Crystal) (Entered: 08/05/2020)
08/06/2020 8 MOTION for Continuance of Initial Pretrial Conference by Jeanie Hicks, filed. Motion Docket Date 8/27/2020. (EdnitaPonce, 1) (Entered: 08/06/2020)
08/07/2020 9 NOTICE of Resetting. Parties notified. Initial Conference set for 10/2/2020 at 09:00 AM in Courtroom 8C before Judge Alfred H Bennett, filed. (ledwards, 4) (Entered: 08/07/2020)
10/02/2020 10 SCHEDULING ORDER. Amended Pleadings due by 10/9/2020. Pltf Expert Report due by 12/4/2020. Deft Expert Report due by 12/18/2020. Discovery due by 11/6/2020. Dispositive Motion Filing due by 1/15/2021. Non-Dispositive Motion Filing due by 1/15/2021. Joint Pretrial Order due by 3/8/2021. Pretrial Conference set for 3/26/2021 at 01:30 PM in Courtroom 8C before Judge Alfred H Bennett Docket Call set for 3/29/2021 at 09:00 AM in Courtroom 8C before Judge Alfred H Bennett(Signed by Judge Alfred H Bennett) Parties notified.(ledwards, 4) (Entered: 10/02/2020)
10/02/2020 11 NOTICE of Setting. Parties notified. Status Conference set for 1/8/2021 at 10:00 AM in Courtroom 8C before Judge Alfred H Bennett, filed. (ledwards, 4) (Entered: 10/02/2020)
11/30/2020 12 CLERKS NOTICE of Status Hearing. A status hearing is scheduled in this case January 8, 2021 at 10:00 a.m. via Zoom. Parties will receive connection instructions the day before the hearing. Parties notified, filed. (ledwards, 4) (Entered: 11/30/2020)
12/16/2020 13 Expert Report of Crystal Gee Gibson by Cenlar FSB, filed.(Gibson, Crystal) (Entered: 12/16/2020)
01/08/2021 14 CLERKS NOTICE of Status Conference. A status conference is scheduled April 30, 2021 at 10:00 a.m. via Zoom. Parties will receive connection instructions the day before the setting. Parties notified, filed. (ledwards, 4) (Entered: 01/08/2021)
01/20/2021 15 Opposed MOTION to Modify as to 10 Scheduling Order,, by Cenlar FSB, filed. Motion Docket Date 2/10/2021. (Gibson, Crystal) (Entered: 01/20/2021)
02/18/2021 16 SCHEDULING ORDER Granting 15 Opposed MOTION to Modify as to 10 Scheduling Order,,. ( Amended Pleadings due by 5/3/2021., Pltf Expert Report due by 6/28/2021., Deft Expert Report due by 7/12/2021., Discovery due by 7/28/2021., Dispositive Motion Filing due by 8/4/2021., Non-Dispositive Motion Filing due by 8/4/2021., Joint Pretrial Order due by 9/20/2021., Docket Call set for 10/8/2021 at 01:30 PM in Courtroom 8C before Judge Alfred H Bennett, Jury Trial set for 10/12/2021 at 09:00 AM in Courtroom 8C before Judge Alfred H Bennett)(Signed by Judge Alfred H Bennett) Parties notified.(ledwards, 4) (Entered: 02/18/2021)
04/23/2021 17 ORDER Status Conference reset for 5/7/2021 at 10:00 AM in by video before Judge Alfred H Bennett(Signed by Judge Alfred H Bennett) Parties notified.(ledwards, 4) (Entered: 04/23/2021)
05/06/2021 18 STRICKEN FROM THE RECORD per Doc (#22) (Entered: 05/06/2021)
05/06/2021 19 BRIEF in support re: 18 MOTION for Summary Judgment by Cenlar FSB, filed. (Attachments: # 1 Affidavit Rushmore, # 2 Exhibit A-1 Note, # 3 Exhibit A-2 Deed of Trust, # 4 Exhibit A-3 Assignments, # 5 Exhibit A-4 – 5-13-20 NOD, # 6 Exhibit A-5- 7-21-11 NOD, # 7 Exhibit A-6 – payoff, # 8 Exhibit B, Afd and B-1, and B-2, # 9 Exhibit C-Declaration Atty Fees)(Gibson, Crystal) (Entered: 05/06/2021)
05/07/2021 20 NOTICE of Setting. Parties notified. Status Conference reset for 6/5/2021 at 10:00 AM in Courtroom 8C before Judge Alfred H Bennett, filed. (ledwards, 4) (Entered: 05/07/2021)
05/07/2021 21 CORRECTED NOTICE of Resetting. Parties notified. Status Conference set for 7/16/2021 at 10:00 AM in Courtroom 8C before Judge Alfred H Bennett, filed. (ledwards, 4) (Entered: 05/07/2021)
05/10/2021 22 ORDER striking 18 Motion for Summary Judgment.(Signed by Judge Alfred H Bennett) Parties notified.(ledwards, 4) (Entered: 05/10/2021)
05/10/2021 23 NOTICE of Appearance by Shelley L. Hopkins on behalf of Cenlar FSB, filed. (Hopkins, Shelley) (Entered: 05/10/2021)
07/16/2021 24 Minute Entry for proceedings held before Judge Alfred H Bennett. STATUS CONFERENCE held on 7/16/2021. Ms. Hopkins council for Cenlar FSB gave the Court a status update. Ms. Jeanie Hicks was not present but was aware of the status conference. She was provided with copies of the setting via email and by U.S. postal mail. Appearances: Shelley L. Hopkins.(Court Reporter: Miller), filed.(jguajardo, 4) (Entered: 07/17/2021)
07/28/2021 25 Corrected MOTION for Summary Judgment by Cenlar FSB, filed. Motion Docket Date 8/18/2021. (Attachments: # 1 Affidavit A-Declaration of Cenlar, # 2 Exhibit A-1-Note, # 3 Exhibit A-2-Deed of Trust, # 4 Exhibit A-3-Assignment, # 5 Exhibit A-4-NOD 5-13-20, # 6 Exhibit A-5-payoff, # 7 Exhibit A-6-NOD 7-12-11, # 8 Affidavit B-Declaration of BDFTE, # 9 Affidavit C-Attorney’s Fee Declaration, # 10 Proposed Order)(Gibson, Crystal) (Entered: 07/28/2021)
Sanctioned Lawyer Crystal Gibson of BDF Provides Bennett With A Reason to Stay the Foreclosure Case
Click to comment

Leave a Reply

Your email address will not be published. Required fields are marked *

Laws In Texas is a blog about the Financial Crisis and how the banks and government are colluding against the citizens and homeowners of the State of Texas and relying on a system of #FakeDocs and post-crisis legal precedents, specially created by the Court of Appeals for the Fifth Circuit to foreclose on homeowners around this great State. We are not lawyers. We do not offer legal advice. We are citizens of the State of Texas who have spent a decade in the court system in Texas and have been party to during this period to the good, the bad and the very ugly.

Donate to LawsInTexas. Make a Difference.

Subscribe to Our Newsletter

We keep your data private and share your data only with third parties that make this service possible. See our Privacy Policy for more information.

© 2020-21 LawInTexas com is an online trading name which is wholly owned by Blogger Inc., a nonprofit 501(c)(3) registered in Delaware. | All Rights Reserved.

To Top