The lawyer and Law Firm filing suit is clearly a debt collector, one without a valid, active surety bond with TX SOS.
This Texas 'foreclosure defense' lawyer should be called Erick DeLaRogue as his client stole $200k from non-citizens or illegal aliens.
The only parties allowed in HC District Court are criminals and miscreants. The Outlaws in Dirty Robes prefer 'em to honest litigants.
Lawyer Manookian has displayed a custom and habit of threatening opposing counsel and third parties for no reasonably legitimate purpose.