In Re ColossusBets Limited v. the State of Texas

ACCEPTED
15-25-00150-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
10/9/2025 9:21 PM
CHRISTOPHER A. PRINE
CLERK
FILED IN
15th COURT OF APPEALS
No.15-25-00150-CV AUSTIN, TEXAS
10/9/2025 9:21:09 PM
__________________________________________________________________
CHRISTOPHER A. PRINE
Clerk

15th Court of Appeals of Texas

__________________________________________________________________

In Re ColossusBets Limited, Relator

_________________________________________________________________

REAL PARTY IN INTEREST JERRY B. REED’S RESPONSE
TO PETITION FOR WRIT OF MANDMAMUS
_________________________________________________________________

Original Proceeding from Cause No. 25-BC03A-0007
Business Court of Texas Third Division Austin, Texas

__________________________________________________________________

LAGARDE LAW FIRM, P.C.
Richard L. LaGarde
State Bar No. 11819550
Mary LaGarde
State Bar No. 24037645
230 Westcott St., Suite 100
Houston, TX 77007
TEL: (713) 993-0660
richard@lagardelaw.com
mary@lagardelaw.com
ATTORNEYS FOR REAL
PARTY IN INTEREST
TABLE OF CONTENTS

ISSUES PRESENTED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
SUMMARY OF ARGUMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
I. The Business Court Never Had Subject-Matter Jurisdiction . . .4
II. Even if Jurisdiction Attached Initially, the “One-Way Door”
Theory Is Wrong And Dangerous. . . . . . . . . . . . . . . . . . . . . . . . . 6
III. Mandamus Is Not Proper. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
STANDARD OF REVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
ARGUMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

I. THE BUSINESS COURT ERRED IN ASSERTING SUBJECT-
MATTER JURISDICTION IN THE FIRST PLACE . . . . . . . . . . . . . . . . 9
A. The Business Court’s June 18, 2025 order denying remand rested
on a fundamentally overbroad interpretation of Tex. Gov’t Code §
25A.004(b)(2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
B. Mere Introduction of Governing Documents as Evidence Does
Not Trigger Business Court Jurisdiction . . . . . . . . . . . . . . . . . . . . . . . . 10
C. The “Vehicle to Conceal Identities” Allegation Did Not Convert
the Case into a Governance Dispute . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
D. Statutory Context Confirms That § 25A.004(b)(2) Is Meant for
Internal Disputes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
E. The Court’s “Entire Action” Holding Magnifies the Error . . . . .15
F. The Purported “Governing Documents Hook” Was Legally
Insufficient . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
G. The Court can affirm on this narrow ground . . . . . . . . . . . . . . 17

i
II. EVEN IF JURISDICTION ATTACHED, THE “ONE-WAY DOOR”
THEORY IS LEGALLY AND PRACTICALLY UNSOUND . . . . . . . . . 17
A. Subject-Matter Jurisdiction Depends on Live Pleadings . . . . .17
B. Continental Coffee Does Not Bar Jurisdictional Reassessment
After Pleading Amendments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
C. Subject-Matter Jurisdiction Must Be Determined from the Live
Pleadings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
D. Relator’s “One-Way Door” Theory Conflicts with Legislative
Design and Sound Judicial Administration. . . . . . . . . . . . . . . . . . . . . . . 21
E. Colossus’s “One-Way Door” Theory Misreads Chapter 25A and
Conflicts with Texas Jurisdictional Law . . . . . . . . . . . . . . . . . . . . . . . . 24
F. The Statutory Text Does Not Make Jurisdiction Irrevocable Once
Initially Established . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
G. The Absence of Federal “At Any Time” Language Does Not
Eliminate Texas Courts’ Ongoing Duty to Reassess Jurisdiction . . . . . 27
H. North Carolina’s Business Court Is Not Analogous to Texas’s
System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
I. Why This Matters for “One-Way Door” . . . . . . . . . . . . . . . . . . . 31
J. Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

III. MANDAMUS RELIEF IS NOT WARRANTED . . . . . . . . . . . . . . . . . 32

A. Mandamus Is an Extraordinary Remedy, Not a Substitute for
Appeal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

B. Adequate Appellate Remedies Exist . . . . . . . . . . . . . . . . . . . . .32

C. Relator’s “Systemic Importance” Argument Is Overstated . . . .34

D. Relator Has Not Shown Any Concrete Prejudice or
Irreparable Harm . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

ii
E. Granting Mandamus Here Would Improperly Expand
Mandamus Jurisdiction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

F. Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

PRAYER . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
CERTIFICATE OF SERVICE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
CERTIFICATE OF COMPLIANCE . . . . . . . . . . . . . . . . . . . . . . . . . . 37

iii
TABLE OF AUTHORITIES
CASES
Austin & N.W.R. Co. v. Cluck, 97 Tex. 172, 77 S.W. 403 (1903)…… 29
City of Ingleside v. City of Corpus Christi, 469 S.W.3d 589 (Tex.
2015)………………………………………………………………………… 33
Composite Fabrics of Am., LLC v. Edge Structural Composites,
Inc., 2016 NCBC LEXIS 11 (N.C. Bus. Ct. Feb. 5, 2016)…………... 28
Continental Coffee Prods. Co. v. Cazarez, 937 S.W.2d 444
(Tex. 1997)………………………………………………………………….. 18
County of Cameron v. Brown, 80 S.W.3d 549 (Tex. 2002)………….. 19
Dubai Petroleum Co. v. Kazi, 12 S.W.3d 71 (Tex. 2000)…………….. 9
Holloway v. Fifth Court of Appeals, 767 S.W.2d 680 (Tex. 1989)….. 9
In re Prudential Ins. Co. of Am., 148 S.W.3d 124 (Tex. 2004)……… 32
Isbell v. Kenyon-Warner Dredging Co., 113 Tex. 528, 261 S.W. 762
(1924)………………………………………………………………………... 26
Olds v. Olds, 2025 NCBC Order 57 (N.C. Bus. Ct. Aug. 13, 2025)... 28
Rivercenter Assocs. v. Rivera, 858 S.W.2d 366 (Tex. 1993)…………. 9
Rusk State Hosp. v. Black, 392 S.W.3d 88 (Tex. 2012)……………… 17
State Bar of Tex. v. Gomez, 891 S.W.2d 243 (Tex. 1994)……………. 30
Tex. Ass’n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440 (Tex.
1993)………………………………………………………………………… 26
Tex. Dep’t of Parks & Wildlife v. Miranda, 133 S.W.3d 217 (Tex.
2004)………………………………………………………………………… 17
Walker v. Packer, 827 S.W.2d 833 (Tex. 1992) (orig. proceeding)…. 8

STATUTES
Tex. Gov’t Code § 25A.004(b)……………………………………………. 14
Tex. Gov’t Code § 25A.004(b)(2)………………………………………... 4
Tex. Gov’t Code § 25A.004(d)……………………………………………. 13
Tex. Gov’t Code § 25A.004(f)…………………………………………….. 15
Tex. Gov’t Code § 25A.006(d)……………………………………………. 2
Tex. Gov’t Code ch. 25A………………………………………………….. 3

RULES
Tex. R. Civ. P. 91a.1………………………………………………………. 18
iv
Tex. R. Civ. P. 91a.5………………………………………………………. 18
Tex. R. App. P. 9.4(i)(1)…………………………………………………... 37
Tex. R. App. P. 9.4(i)(2)(B)………………………………………………. 37

OTHER AUTHORITIES
Jack Buckley DiSorbo, A Primer on the Texas Business Court,
76 Baylor L. Rev. 360 (2024)…………………………………………….. 14

v
TO THE HONORABLE FIFTHTEENTH COURT OF APPEALS:

Real Party in Interest, Jerry B. Reed, respectfully asks the Court to

deny ColossusBets Limited’s Petition for Writ of Mandamus.

ISSUES PRESENTED

1. Subject-Matter Jurisdiction

Did the Business Court possess subject-matter jurisdiction over

this case at any point?

2. “One-Way Door” Theory

Even if the Business Court initially had jurisdiction, does Texas law

recognize a “one-way door” theory that bars remand when subsequent

amendments eliminate the jurisdictional basis?

3. Mandamus Remedy

Whether mandamus relief is available where an adequate remedy

by appeal exists to challenge a remand order on subject-matter

jurisdiction grounds.

INTRODUCTION

ColossusBets seeks the extraordinary and discretionary remedy of

mandamus to overturn a straightforward remand order based on

Plaintiff’s amended live pleadings. The Business Court correctly

Page 1 of 37
recognized that, once Plaintiff amended his petition to withdraw the only

alleged jurisdictional basis, it no longer had subject-matter jurisdiction

and was required by statute to remand the case to district court. See Tex.

Gov’t Code § 25A.006(d).

Under settled Texas law, subject-matter jurisdiction is

fundamental—it cannot be created by consent, preserved by waiver, or

frozen by prior rulings. Jurisdiction is determined from the live pleadings

and must be reassessed whenever those pleadings change. Courts

therefore have both the power and the duty to revisit jurisdiction as

pleadings evolve.

Texas law recognizes no concept of “jurisdictional estoppel.” Once

pleadings change, jurisdiction must be re-examined; it cannot be “locked

in” by an earlier interlocutory ruling. Any contrary rule would nullify the

Legislature’s command that a Business Court “shall” remand a case

when it determines jurisdiction is lacking. See Tex. Gov’t Code §

25A.006(d). The Business Court faithfully applied that statutory

directive here.

Mandamus is not available to overturn such a routine jurisdictional

ruling. It is an extraordinary remedy reserved for clear abuses of

Page 2 of 37
discretion when there is no adequate remedy by appeal. The expense or

delay of litigating in district court does not render appeal inadequate,

and the novelty of a legal question does not justify extraordinary relief.

Because the Business Court correctly recognized its lack of jurisdiction,

Relator cannot satisfy either prong of the mandamus standard.

From the outset, this case has had nothing to do with corporate

governance. It arises from a sophisticated fraudulent-lottery scheme that

diminished Plaintiff Jerry Reed’s rightful jackpot by more than $52

million. The alleged misconduct occurred before Rook TX LP or Rook GP

LLC even existed and involved counterfeit QR codes and mass printing

of invalid tickets—not the rights, duties, or internal operations of a

business entity. The Business Court therefore lacked jurisdiction from

the start under Chapter 25A, which narrowly confines its docket to

internal-affairs disputes among business owners.

The Legislature created the Business Court to resolve genuine

corporate-governance controversies, not to warehouse cases that have

ceased to involve such issues. Relator’s “one-way door” theory would

expand the court’s reach far beyond its statutory mission, forcing it to try

ordinary tort and restitution claims contrary to Chapter 25A’s limited

Page 3 of 37
design. The Business Court’s remand order avoided precisely that

overreach by returning this matter to a court of general jurisdiction.

The petition should be denied.

SUMMARY OF ARGUMENT

I. The Business Court Never Had Subject-Matter Jurisdiction.

Plaintiff’s claims have always targeted external fraud, restitution,

and conspiracy—not internal governance matters. The narrow

jurisdictional grant in Tex. Gov’t Code § 25A.004(b)(2) applies only to

actions “regarding the governance, governing documents, or internal

affairs” of an organization. This case does not fit that description. At the

time of removal, Plaintiff’s live claims were for money had and received,

civil conspiracy, aiding and abetting, assisting and participating, concert

of action, and negligence per se—all arising from defendants’ fraudulent

conduct surrounding a rigged lottery scheme. None of these claims

constitute an action regarding Rook’s internal governance, its governing

documents, or its internal affairs. Removal to the Business Court by Rook

was therefore improper from the outset.

Page 4 of 37
Defendants manufactured a basis for Business Court removal by

seizing on allegations that Rook misrepresented its date of formation

when it collected the lottery jackpot. But those allegations were never the

gravamen of Plaintiff’s claims; they were background facts providing

context for the broader fraud scheme. The fraud claim against Rook was

later dropped for substantive legal reasons—not as a tactical maneuver.

Rook itself filed a Rule 91a motion demonstrating that, even if it

misrepresented its formation date to the Lottery Commission, that

misrepresentation could not have proximately caused Plaintiff’s injury.

The premature end of the roll cycle and resulting jackpot reduction were

caused by the earlier mass-printing of invalid tickets using illegal

methods, not by Rook’s subsequent statements regarding its formation

date. Once that legal defect became clear, Plaintiff appropriately

narrowed the claims by amendment. This was not forum shopping; it was

a proper and necessary response to defendants’ own legal challenge.

Because Plaintiff’s claims never fell within § 25A.004(b)(2), the

Business Court erred from the outset in asserting subject-matter

jurisdiction where none existed. The August 25, 2025 remand order

simply corrected that original jurisdictional error.

Page 5 of 37
II. Even if Jurisdiction Attached Initially, the “One-Way Door”
Theory Is Wrong And Dangerous.

Texas law determines jurisdiction by the live pleadings and allows

courts to revisit jurisdiction when claims are amended or dismissed.

Chapter 25A does not freeze subject-matter jurisdiction at removal. A

“one-way door” rule would force the Business Court to try cases wholly

unrelated to its statutory mission after amendments or Rule 91a

dismissals—wasting judicial resources and distorting legislative design.

III. Mandamus Is Not Proper.

Even if the issues were debatable, Relator cannot show clear abuse

of discretion or lack of adequate appellate remedy. Jurisdictional rulings

are routinely reviewed on appeal after final judgment. This is not the

type of extraordinary case warranting mandamus.

BACKGROUND

Plaintiff Jerry Reed held a legitimate winning Lotto Texas ticket

for the May 17, 2023 drawing. He alleges that ColossusBets and related

entities conspired to rig the April 22, 2023 drawing by using counterfeit

QR codes and unauthorized access to official lottery terminals to print

tickets representing nearly every one of the 25.8 million possible number

Page 6 of 37
combinations, thereby guaranteeing themselves the $95 million jackpot.

This legally invalid “win” prematurely ended the roll cycle and reduced

the jackpot pool available for subsequent drawings, including Reed’s.

Defendants’ scheme destabilized the Texas Lottery itself. The

fallout was swift: the Governor ordered a Texas Rangers investigation;

the Lieutenant Governor publicly called it the “biggest fraud ever

perpetrated on the Texas Lottery”; the Executive Director of the Lottery

Commission resigned; and the Legislature dissolved the Commission

altogether.

Mr. Reed filed suit on April 8, 2025, in Travis County District Court.

On May 9, 2025, Rook GP, LLC and Rook TX, LP (hereinafter collectively

referred to as “Rook”) removed the case to the Business Court, contending

that allegations that the Rook defendants misrepresented their date of

formation when they collected the jackpot triggered subject-matter

jurisdiction under Tex. Gov’t Code § 25A.004(b)(2).

Mr. Reed moved to remand, explaining that the mere fact the court

might consult governing documents to determine the Rook entities’

formation date did not transform the case into an action “regarding the

governance, governing documents, or internal affairs” of an organization.

Page 7 of 37
On June 18, 2025, the Business Court denied the motion to remand,

adopting an expansive view of its jurisdiction.

Later, Rook filed a Rule 91a motion arguing that, even if it

misrepresented its formation date to the Lottery Commission, such a

misrepresentation could not have been a proximate cause of Reed’s injury

because the jackpot reduction resulted from the earlier printing of the

allegedly invalid tickets. Confronted with this correct legal point,

Plaintiff filed an amended petition, expressly removing allegations of

fraud regarding Rook’s formation date because they were not legally

viable. This amendment was a substantive response to a pleading defect

identified by defendants—not forum shopping.

On August 25, 2025, Judge Andrews granted Reed’s renewed

motion to remand, holding that the Business Court no longer had

jurisdiction under § 25A.004(b)(2). ColossusBets now seeks mandamus to

undo that remand.

STANDARD OF REVIEW

Mandamus is an extraordinary and discretionary remedy,

available only in limited circumstances to correct a clear abuse of

discretion when there is no adequate remedy by appeal. Walker v. Packer,

Page 8 of 37
827 S.W.2d 833, 839–42 (Tex. 1992) (orig. proceeding) (holding that

appeal is not inadequate merely because it entails expense or delay).

Mandamus “is not issued as a matter of right.” Rivercenter Assocs. v.

Rivera, 858 S.W.2d 366, 367 (Tex. 1993).

The requirement that a relator establish the lack of an adequate

appellate remedy is a “fundamental tenet” of mandamus practice.

Holloway v. Fifth Court of Appeals, 767 S.W.2d 680, 684 (Tex. 1989).

Subject-matter-jurisdiction determinations are reviewed de novo, Dubai

Petroleum Co. v. Kazi, 12 S.W.3d 71, 76–77 (Tex. 2000), but that does not

relax the stringent prerequisites for mandamus. See Walker, 827 S.W.2d

at 839–42; Rivercenter, 858 S.W.2d at 367.

ARGUMENT

I. THE BUSINESS COURT ERRED IN ASSERTING SUBJECT-
MATTER JURISDICTION IN THE FIRST PLACE

A. The Business Court’s June 18, 2025 order denying
remand rested on a fundamentally overbroad
interpretation of Tex. Gov’t Code § 25A.004(b)(2).

Judge Andrews concluded that the case fell within the Business

Court’s jurisdiction because (1) determining whether the Rook entities

misrepresented their formation date “necessarily” implicates their

Page 9 of 37
governing documents, and (2) allegations that the Rook entities were

formed as a vehicle to conceal the identities of other defendants

implicates their internal governance. Neither rationale withstands

scrutiny.

B. Mere Introduction of Governing Documents as Evidence
Does Not Trigger Business Court Jurisdiction.

The Business Court’s first rationale effectively holds that any

lawsuit requiring examination of an entity’s formation papers

automatically becomes “an action regarding the…governing documents”

of an organization. That interpretation is inconsistent with both the text

and structure of § 25A.004(b)(2).

Section 25A.004(b)(2) applies only to “an action regarding the

governance, governing documents, or internal affairs” of an organization.

The Legislature’s use of “regarding” requires that the subject of the action

itself concern governing documents—not that such documents might be

referenced incidentally as evidence. As Reed’s Reply Brief explained, the

June 18 Order improperly collapses subject matter into evidentiary

mechanics, transforming routine evidentiary references into

jurisdictional hooks.

Page 10 of 37
Courts routinely review governing documents as evidence in

standard civil disputes, such as contract, fraud, or agency cases, without

thereby converting those disputes into internal-governance

controversies. If Judge Andrews’ interpretation were correct, Business

Court jurisdiction would swallow much of the civil docket, contrary to the

Legislature’s deliberate choice to limit § 25A.004(b) to a narrow class of

governance disputes.

The text of § 25A.004(b)(2) simply does not support this expansive

reading. The Legislature did not write “actions that reference governing

documents”; it wrote “actions regarding” such documents. The Business

Court’s construction therefore exceeds the statute’s textual bounds.

C. The “Vehicle to Conceal Identities” Allegation Did Not
Convert the Case into a Governance Dispute

The court’s second rationale—that allegations Rook was formed “as

a vehicle to conceal the identities of the members” necessarily implicate

internal governance—misapprehends the legal nature of those

allegations.

An entity’s purpose or motive for formation is not the same as an

internal governance dispute under Tex. Gov’t Code § 25A.004(b)(2).

Page 11 of 37
Jurisdiction under that provision turns on whether the action involves

matters such as the rights, duties, or powers of members, managers, or

governing documents—not on why individuals created a business entity

in the first place or how they later used it. Alleging that other defendants

formed Rook as part of a broader fraudulent scheme does not require

adjudication of Rook’s internal affairs any more than alleging that a shell

company was used to launder funds would transform a money-

laundering prosecution into a corporate governance case.

If mere allegations about why an entity was formed could trigger

Business Court jurisdiction, virtually every fraud or veil-piercing case

would be swept into the Business Court—an outcome plainly inconsistent

with Chapter 25A’s structure, which reserves jurisdiction for genuine

internal-affairs disputes, not generalized fraud allegations.

The gravamen of these allegations concerns external conduct:

defendants allegedly rigged the lottery and used Rook as a façade to hide

the participants’ identities. Resolving those issues involves tracing

fraudulent actions and financial flows—not interpreting operating

agreements, determining member rights, or adjudicating corporate

control disputes. The Business Court’s attempt to treat motive-for-

Page 12 of 37
formation allegations as governance issues improperly stretches §

25A.004(b)(2) far beyond its text and purpose.

D. Statutory Context Confirms That § 25A.004(b)(2) Is
Meant for Internal Disputes

Reading § 25A.004(b)(2) in context confirms the error. Adjoining

subsections (b)(1) and (b)(3)–(7) address internal disputes among owners

and fiduciaries, such as derivative actions and fiduciary duty claims. By

contrast, external commercial disputes are addressed in subsection (d),

with higher amount-in-controversy thresholds. This internal–external

structure was a deliberate legislative choice.

One legal commentator has described all seven categories of actions

outlined in § 25A.004(b)(1)–(7) as “internal” business disputes,

contrasting them with the “external” business disputes outlined in §

25A.004(d)(1)–(3):

Page 13 of 37
The first category of cases that fall within the
Business Court’s jurisdiction are those in which
the amount in controversy exceeds $5 million
and the subject concerns at least one of several
subjects…. Together, these categories cover
most forms of internal business disputes; i.e.,
disputes about the business’s management,
claims between shareholders and the company,
and so on. External business disputes, i.e.,
actions involving a company and a separate
person or business, are reserved for the next
category of jurisdiction, where the amount in
controversy is heightened to $10 million.

Jack Buckley DiSorbo, A Primer on the Texas Business Court, 76 Baylor

L. Rev. 360, 371-72 (2024).

There are seven categories of actions listed in Tex. Gov’t Code §

25A.004(b). Subsections (b)(1), and (b)(3)-(7) reveal a pattern of internal

disputes-- actions that directly challenge or seek to enforce specific rights

or duties of shareholders, owners, and managers of Texas businesses.

These six subsections target actions that are inherently about corporate

law matters, not actions that merely touch upon them tangentially.

Applying the in pari materia principle, courts should interpret subsection

(b)(2) in harmony with the other six adjoining subsections, all of which

focus on internal business disputes. By contrast, Plaintiff’s claims belong

in the category of external business disputes—conflicts between a third

Page 14 of 37
party and the defendants—rather than internal governance disputes

among entity insiders. Defendants' effort to reframe the case as an

internal business dispute falling within the jurisdiction of the Business

Court was, at best, disingenuous.

The Business Court’s interpretation of its own subject-matter

jurisdiction obliterates the legislative structure by sweeping into (b)(2)

any external dispute in which governing documents might be consulted

for evidentiary purposes, thereby erasing the line between subsections

(b) and (d). That is not what the Legislature intended.

E. The Court’s “Entire Action” Holding Magnifies the Error

Having found that an incidental issue supposedly fell within §

25A.004(b)(2), Judge Andrews asserted jurisdiction over the entire

action, reasoning that the statute speaks in terms of “actions” rather than

“claims” (Op. at 7–8) . This approach sidesteps § 25A.004(f), which makes

supplemental jurisdiction over non-(b) claims consensual. If allowed to

stand, the Business Court’s reasoning would enable defendants to

bootstrap entire cases into the Business Court based on a fleeting,

collateral reference to a governing document—without satisfying the

statute’s express safeguards.

Page 15 of 37
F. The Purported “Governing Documents Hook” Was
Legally Insufficient

Finally, the jurisdictional hook defendants identified—the alleged

misrepresentation of Rook’s formation date necessitating a reference to

governing documents—was legally insubstantial. Rook’s own Rule 91a

motion explained that any such misrepresentation could not have

proximately caused Reed’s injury, because the jackpot reduction

stemmed from the earlier counterfeit-ticket scheme. Reed accordingly

dropped the fraud claim by amendment after Rook filed its Rule 91a

motion. A non-viable theory cannot support subject-matter jurisdiction.

This reinforces that the Business Court never had jurisdiction to begin

with.

In short: The Business Court’s June 18 order erred because it (1)

treated incidental evidentiary references as dispositive of jurisdiction, (2)

mischaracterized allegations about other defendants’ motives as Rook’s

governance issues, (3) ignored the statute’s internal–external structure,

(4) improperly extended jurisdiction to the entire action, and (5) relied on

a legally deficient jurisdictional hook. The August 25 remand order

merely corrected this initial error, and ColossusBets cannot use

Page 16 of 37
mandamus to revive a jurisdictional theory that the statute does not

support.

G. The Court can affirm on this narrow ground.

Because the Business Court never had jurisdiction in the first

place, the remand order simply corrected an error. No “one-way door”

issue need be reached.

II. Even If Jurisdiction Attached, The “One-Way Door” Theory Is
Legally And Practically Unsound.

A. Subject-Matter Jurisdiction Depends on Live Pleadings.

Texas law is clear that subject-matter jurisdiction is determined

from the live pleadings. When pleadings are amended, the court must

reassess subject-matter jurisdiction in light of the new allegations. Tex.

Dep’t of Parks & Wildlife v. Miranda, 133 S.W.3d 217, 226–27 (Tex. 2004)

(holding that courts determine jurisdiction from the pleadings and must

afford amendment if jurisdictional defects are curable), reaffirmed by

Rusk State Hosp. v. Black, 392 S.W.3d 88, 95 (Tex. 2012) (holding that

courts determine jurisdiction from the live pleadings and jurisdictional

evidence, granting leave to amend where appropriate).

Page 17 of 37
Rule 91a reinforces this principle by requiring the court to decide a

motion to dismiss based on the then-operative petition and by permitting

amendment before the hearing. Tex. R. Civ. P. 91a.1, 91a.5.

Section 25A.006(d) likewise mandates remand “if removal was

improper.” Nothing in the statute freezes jurisdiction at the moment of

removal; courts must examine jurisdiction under the live pleadings as

they exist when the issue is decided.

B. Continental Coffee Does Not Bar Jurisdictional
Reassessment After Pleading Amendments.

Colossus’s reliance on Continental Coffee Products Co. v. Cazarez,

937 S.W.2d 444 (Tex. 1997), is misplaced. Continental Coffee involved a

statutory county court’s monetary jurisdiction, not limited subject-

matter jurisdiction. There, the plaintiff’s original petition properly

alleged an amount in controversy within the court’s monetary

jurisdictional limits, but later amendments increased the damages

sought due to the passage of time. The Texas Supreme Court held that

this did not divest jurisdiction because “jurisdiction is based on the

allegations in the petition about the amount in controversy” and “as a

Page 18 of 37
general rule, where jurisdiction is once lawfully and properly acquired,

no later fact or event can defeat the court’s jurisdiction.” Id. at 449.

That rule applies narrowly to cases where jurisdictional amount is

properly pleaded and later factual developments—such as the passage of

time—cause damages to increase. It has no application to a Business

Court case in which the plaintiff amends the live petition to remove the

only statutory category supporting subject-matter jurisdiction under Tex.

Gov’t Code § 25A.004(b). Unlike amount-in-controversy rules, the

Business Court’s limited subject-matter jurisdiction depends on the

continued presence of qualifying allegations in the live pleadings. When

those allegations are withdrawn, the court’s statutory jurisdiction ceases,

and § 25A.006(d) mandates remand. Continental Coffee did not involve,

and does not govern, that circumstance.

Texas law is clear that subject-matter jurisdiction is determined

from the live pleadings. When those pleadings are amended, courts must

reassess jurisdiction in light of the new allegations. Tex. Dep’t of Parks &

Wildlife v. Miranda, 133 S.W.3d 217, 226–27 (Tex. 2004); County of

Cameron v. Brown, 80 S.W.3d 549, 555 (Tex. 2002). Additionally, §

25A.006(d) of the Government Code mandates that “[i]f the business

Page 19 of 37
court does not have jurisdiction of the action, the business court shall

remand the action to the court in which the action was originally filed,”

underscoring that jurisdiction is not frozen at the moment of removal but

must be assessed under the pleadings as they exist when the issue is

decided.

In short, Continental Coffee does not prevent a court of statutorily

limited subject-matter jurisdiction from recognizing that jurisdiction

never validly attached, or that amended pleadings eliminated the only

alleged jurisdictional basis. That is precisely what occurred here: the

Business Court’s initial assertion of jurisdiction was erroneous, and Mr.

Reed’s amended petition removed the only purported jurisdictional hook.

Under settled Texas law, the Business Court properly revisited its

jurisdiction and remanded the case.

Relator’s invocation of Continental Coffee is therefore inapposite.

The relevant authorities are those addressing subject-matter

jurisdictional pleading amendments, not finality principles arising in

unrelated monetary-jurisdiction contexts.

Page 20 of 37
C. Subject-Matter Jurisdiction Must Be Determined from
the Live Pleadings.

The Texas Supreme Court has consistently held that subject-matter

jurisdiction depends on the live pleadings at the time of the

jurisdictional ruling. Miranda, 133 S.W.3d at 226–27; Rusk State Hosp.,

392 S.W.3d at 95. When an amended petition removes the jurisdictional

facts, jurisdiction is lost. That is precisely what occurred here: Plaintiff’s

amended petition eliminated the jurisdictional hook on which Business

Court jurisdiction rested. Because the live pleading no longer invoked

Business Court jurisdiction, the Business Court correctly determined

that it lacked subject-matter jurisdiction and remanded. This ruling was

not an abuse of discretion, and mandamus does not lie to compel a court

to exercise subject-matter jurisdiction it does not possess.

D. Relator’s “One-Way Door” Theory Conflicts with
Legislative Design and Sound Judicial Administration.

Relator’s “one-way door” theory would produce results the

Legislature could not have intended. If jurisdiction were permanently

fixed at the moment of removal—even where later pleadings or Rule 91a

dismissals eliminate the sole jurisdictional hook—the Business Court

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would be compelled to retain and adjudicate cases wholly unrelated to

the subject matters assigned to it by statute.

This case illustrates the problem. Even under the Business Court’s

initial view, the alleged jurisdictional basis was an incidental reference

to Rook’s formation date. Once that legally insubstantial allegation was

removed by amendment, the case involved only external fraud,

restitution, and conspiracy claims concerning the rigging of a lottery

drawing. Forcing the Business Court to retain such a case—despite the

absence of any live governance or internal-affairs issue—would squander

specialized judicial resources and distort the court’s intended role.

The problem is not hypothetical. Suppose the sole jurisdictional

cause of action relied upon for removal is dismissed early in the litigation

under Rule 91a. Under Relator’s theory, the Business Court would

nonetheless be required to proceed to trial in a case bearing no connection

to its statutory mission. That outcome would subvert both the text and

structure of Chapter 25A.

Chapter 25A was enacted to create specialized dockets for complex

business governance disputes, not to convert the Business Court into a

general civil trial court of plenary jurisdiction. Subsections (b)(1)–(7)

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carefully delineate the types of internal business disputes that qualify,

while subsection (d) addresses high-value external commercial disputes.

Reading the statute as Relator proposes would collapse this carefully

drawn structure, pulling tort, restitution, and negligence cases into the

Business Court merely because of allegations that are later withdrawn

or dismissed.

Worse still, Relator’s rule would create perverse incentives.

Defendants could remove cases to the Business Court based on tenuous,

incidental allegations and then resist remand even after those

allegations are eliminated by amendment or Rule 91a dismissal. This

would invite gamesmanship, allow defendants to manipulate forum

selection, and burden the Business Court with cases having no

meaningful connection to its core subject matter.

By contrast, the rule applied by Judge Andrews—that jurisdiction

must be reassessed based on the live pleadings—is faithful to the

statutory text and consistent with sound judicial administration. It

ensures that the Business Court adjudicates only those disputes the

Legislature actually assigned to it, while allowing ordinary tort, fraud,

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and restitution cases to proceed in the general district courts where they

belong.

E. Colossus’s “One-Way Door” Theory Misreads Chapter
25A and Conflicts with Texas Jurisdictional Law.

Colossus advances three reasons why, in its view, the Business

Court should not reassess subject-matter jurisdiction after it has once

been established: (1) that Chapter 25A provides for a “prompt and final”

one-time jurisdictional determination; (2) that Texas law, unlike federal

removal statutes, does not authorize remand “at any time” before

judgment; and (3) that North Carolina’s business court system treats

jurisdiction as a “one-way door” and Texas should do likewise. Pet. at 27–

34. Each contention fails.

F. The Statutory Text Does Not Make Jurisdiction
Irrevocable Once Initially Established

Colossus first relies on scattered provisions of Chapter 25A and

Rule 355(f)(1) to argue that the Business Court makes a single, “prompt

and final” determination of jurisdiction at the time of removal, after

which jurisdiction cannot be revisited. Pet. at 27–29. According to

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Colossus, once removal is “proper,” subject-matter jurisdiction is fixed

“for the rest of the life of the case.” Id. at 27.

That is incorrect. Nothing in Chapter 25A provides that subject-

matter jurisdiction, once determined, is irrevocable. Section 25A.006(d)

expressly provides that the Business Court “shall” remand the case if the

court determines that it does not have jurisdiction. Tex. Gov’t Code §

25A.006(d) (emphasis added). The statute does not limit that obligation

to defects existing only at the moment of removal. If, at any time

thereafter, the live pleadings no longer allege facts bringing the case

within Chapter 25A, then the Business Court “does not have

jurisdiction,” and remand is mandatory. Id.

Colossus’s reading also conflicts with settled Texas law that

subject-matter jurisdiction depends on the live pleadings at the time the

court rules. Tex. Dep’t of Parks & Wildlife v. Miranda, 133 S.W.3d 217,

226–27 (Tex. 2004) (holding that courts determine jurisdiction from the

pleadings and must afford amendment if jurisdictional defects are

curable), reaffirmed by Rusk State Hosp. v. Black, 392 S.W.3d 88, 95 (Tex.

2012) (holding that courts determine jurisdiction from the live pleadings

and jurisdictional evidence, granting leave to amend where appropriate).

Page 25 of 37
Courts have both the power and the duty to reassess jurisdiction

whenever pleadings change. County of Cameron v. Brown, 80 S.W.3d 549,

555 (Tex. 2002) (holding that courts must examine pleadings to

determine jurisdiction and reassess jurisdiction if pleadings change,

granting leave to amend if defects are curable); Isbell v. Kenyon-Warner

Dredging Co., 113 Tex. 528, 261 S.W. 762, 763 (1924) (holding that when

an amended petition sets up a new cause of action and abandons the old,

it “speaks from its own date” and must itself support jurisdiction).

That is precisely what happened here: Plaintiff’s amended petition

removed the jurisdictional allegations that initially invoked Business

Court jurisdiction. The Business Court properly reassessed its

jurisdiction based on the amended pleading, as Texas law requires.

Finally, Colossus’s policy concerns about efficiency and stability

cannot override jurisdictional limits. Texas courts have repeatedly

rejected attempts to create jurisdiction by waiver, consent, or prior

rulings. Tex. Ass’n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 443–

44 (Tex. 1993) (“Subject matter jurisdiction is essential to the authority

of a court to decide a case…. Subject matter jurisdiction is never

Page 26 of 37
presumed and cannot be waived.”). Chapter 25A requires prompt rulings

at removal, not perpetual jurisdiction despite changed pleadings.

G. The Absence of Federal “At Any Time” Language Does
Not Eliminate Texas Courts’ Ongoing Duty to Reassess
Jurisdiction

Colossus next argues that, unlike federal removal statutes, Chapter

25A lacks language authorizing remand “at any time before final

judgment,” demonstrating legislative intent to foreclose later

jurisdictional challenges. Pet. at 29–32. This is a red herring.

Texas courts do not need a statutory “at any time” clause to revisit

subject-matter jurisdiction because Texas law already provides that

jurisdiction can be challenged at any time and cannot be conferred by

waiver, estoppel, or prior interlocutory rulings. Rusk, 392 S.W.3d at 95–

96; Tex. Ass’n of Bus., 852 S.W.2d at 443–44. Courts have an

independent, ongoing obligation to ensure they possess jurisdiction.

Miranda, 133 S.W.3d at 226–27.

Colossus’s argument would make the Business Court unique among

Texas courts—able to retain cases even when its statutory jurisdictional

prerequisites no longer exist. Nothing in Chapter 25A suggests the

Legislature intended to create such a special, jurisdiction-by-estoppel

Page 27 of 37
regime for this new tribunal. To the contrary, § 25A.006(d)’s remand

mandate confirms the Legislature expected the court to remand

whenever it lacks jurisdiction, not just at removal.

H. North Carolina’s Business Court Is Not Analogous to
Texas’s System

Relator’s reliance on Olds v. Olds, 2025 NCBC Order 57 (Aug. 13,

2025), is misplaced for a simple but fundamental reason: North

Carolina’s Business Court is not a separate court of limited subject-

matter jurisdiction but an administrative division of the Superior Court.

As Olds itself explains:

The [Business] Court is merely an
administrative division of the superior court in
the General Court of Justice. A Business Court
judge is a special superior court judge who is
assigned cases that originate from counties
across the state… [and] proceeds with the same
jurisdiction and authority as any other superior
court judge.”

Id. ¶ 13 (quoting Composite Fabrics of Am., LLC v. Edge Structural

Composites, Inc., 2016 NCBC LEXIS 11, at *27).

Subject-matter jurisdiction in North Carolina is vested in the

Superior Court itself. Designation to the Business Court does not alter or

Page 28 of 37
confer jurisdiction, which remains with the Superior Court. Olds, slip op.

at 26–28. Thus, when Olds held that a designation “once ordered” cannot

be withdrawn by later pleading amendments, it addressed case

assignment within a single court of general jurisdiction, not the existence

of subject-matter jurisdiction in a separate court system with limited

statutory jurisdiction.

Texas’s system is entirely different. The Texas Business Court is a

court of limited statutory jurisdiction, distinct from the district courts.

Tex. Gov’t Code § 25A.004(b). A case may remain in the Business Court

only so long as the live pleadings invoke one of the statutory categories

in Chapter 25A. If amended pleadings or a Rule 91a dismissal eliminate

those jurisdictional allegations, the court “shall remand the case.” Tex.

Gov’t Code § 25A.006(d).

This distinction is dispositive. Olds rests on the administrative

nature of North Carolina’s Business Court, which “is not a court of

separate jurisdiction.” Olds, slip op. at 13. Texas Business Courts, by

contrast, are creatures of statute whose jurisdiction exists only when the

Legislature’s conditions are satisfied. Austin & N.W.R. Co. v. Cluck, 97

Tex. 172, 77 S.W. 403, 405 (1903) ("[T]here can be no doubt that the

Page 29 of 37
courts of Texas must look to the Constitution of this state, the

enactments of the Legislature, and the common law for their

authority to proceed ....”)(emphasis added); State Bar of Tex. v. Gomez,

891 S.W.2d 243, 245 (Tex. 1994) ("As a general proposition, before a

court may address the merits of any case, the court must

have…jurisdiction over the subject matter….”)

North Carolina’s “designation” decisions therefore have no bearing

on questions of Texas subject-matter jurisdiction, and Relator’s analogy

fails.

I. Why This Matters for “One-Way Door”.

Relator argues that Texas should adopt North Carolina’s “one-way

door” rule. But that rule only makes sense in North Carolina because a

change in pleadings never affects the Superior Court’s jurisdiction. In

Texas, jurisdiction depends on live pleadings and statutory fit; it can—

and must—be revisited when pleadings change. Tex. Dep’t of Parks &

Wildlife v. Miranda, 133 S.W.3d 217, 226–27 (Tex. 2004); Rusk State

Hosp. v. Black, 392 S.W.3d 88, 95 (Tex. 2012).

Importing North Carolina’s administrative “designation” doctrine

into Texas’s jurisdictional scheme would directly contradict §

Page 30 of 37
25A.006(d)’s remand requirement and longstanding Texas pleading-

based jurisdictional law. It would improperly transform a limited

jurisdiction court into a permanent forum regardless of the claims

actually alleged.

J. Conclusion.

Colossus’s three arguments share a fundamental flaw: they treat

subject-matter jurisdiction as fixed at removal and immune to

subsequent pleading changes. Texas law is to the contrary. Jurisdiction

must exist under the live pleadings at the time of decision, and courts

must reassess it whenever those pleadings change. Miranda, 133 S.W.3d

at 226–27; Rusk, 392 S.W.3d at 95–96. Section 25A.006(d) confirms that

the Business Court must remand when it determines it lacks jurisdiction.

Because Plaintiff’s amended petition eliminated the only

jurisdictional basis for Business Court jurisdiction, the court correctly

concluded it lacked subject-matter jurisdiction and remanded the case.

Colossus’s “one-way door” theory finds no support in Chapter 25A or

Texas precedent, and provides no basis for mandamus relief.

Page 31 of 37
III. MANDAMUS RELIEF IS NOT WARRANTED

A. Mandamus Is an Extraordinary Remedy, Not a
Substitute for Appeal.

Mandamus is “an extraordinary remedy” that is available only

when the trial court has clearly abused its discretion and the relator lacks

an adequate remedy by appeal. In re Prudential Ins. Co. of Am., 148

S.W.3d 124, 135–36 (Tex. 2004). It is not a vehicle to correct ordinary

legal errors or to obtain interlocutory review of interesting or important

legal issues. Id. at 136–37.

Here, Relator’s complaint is that the Business Court erred by

remanding this case for lack of subject-matter jurisdiction. Even if that

were true (it is not), this is a legal issue that can be reviewed and

corrected through the normal appellate process.

B. Adequate Appellate Remedies Exist.

Relator’s core complaint is that the Business Court erred by

remanding the case. But Texas law is clear: jurisdictional rulings can be

fully and effectively reviewed on appeal after final judgment. See Dubai

Petroleum Co. v. Kazi, 12 S.W.3d 71, 76–77 (Tex. 2000) (reviewed on

appeal after judgment, confirming that jurisdictional rulings are

Page 32 of 37
correctable through the ordinary appellate process); City of Ingleside v.

City of Corpus Christi, 469 S.W.3d 589, 590–93 (Tex. 2015) (reviewing

denial of plea to the jurisdiction on direct appeal; illustrating that

jurisdictional issues are correctable through ordinary appellate review).

If the district court ultimately enters judgment, ColossusBets can

raise the Business Court’s remand as an error on appeal. There is nothing

“irremediable” about this situation.

The expense and inconvenience of having to proceed to trial in

district court before appealing the Business Court’s jurisdictional ruling

do not justify mandamus relief. As the Supreme Court explained in

Walker v. Packer, 827 S.W.2d 833, 842 (Tex. 1992):

We further hold that an appellate remedy is
not inadequate merely because it may involve
more expense or delay than obtaining an
extraordinary writ. As we observed in Iley v.
Hughes, the ‘delay in getting questions decided
through the appellate process ... will not justify
intervention by appellate courts through the
extraordinary writ of mandamus. Interference
is justified only when parties stand to lose their
substantial rights.’” (quoting 158 Tex. 362, 368,
311 S.W.2d 648, 652 (1958)).

Unlike cases involving discovery orders threatening privileged

information or ultra vires injunctions, nothing about this remand order

Page 33 of 37
prevents eventual appellate correction. See In re Prudential Ins. Co. of

Am., 148 S.W.3d 124, 136–37 (Tex. 2004) (identifying exceptional

situations warranting mandamus). The ability to appeal and correct any

jurisdictional ruling after final judgment defeats Relator’s claim that

mandamus is necessary here.

C. Relator’s “Systemic Importance” Argument Is
Overstated.

ColossusBets argues that this case presents “an issue of first

impression” concerning Business Court jurisdiction, and that mandamus

is needed to “give guidance.” However, the novelty of a legal issue does

not transform an ordinary jurisdictional ruling into an extraordinary

case warranting mandamus. See In re Prudential Ins. Co. of Am., 148

S.W.3d 124, 136–37 (Tex. 2004) (explaining that mandamus is not

warranted merely because a trial court’s order is wrong or the issue is

important).

The Business Court is new, but that does not make every

jurisdictional disagreement “exceptional.” Indeed, if mandamus became

the default vehicle for every jurisdictional dispute involving the Business

Court, it would flood appellate dockets and short-circuit the ordinary

Page 34 of 37
development of jurisprudence through final judgments. Prudential

explicitly warns against such expansion. 148 S.W.3d at 136–37.

D. Relator Has Not Shown Any Concrete Prejudice or
Irreparable Harm

ColossusBets has not identified any prejudice that cannot be

remedied on appeal. The case is in early procedural posture. The mere

fact that Relator would prefer to litigate in a different forum is not

irreparable harm.

E. Granting Mandamus Here Would Improperly Expand
Mandamus Jurisdiction.

Finally, granting mandamus in this case would open the door for

every remand decision involving Business Court jurisdiction to be

immediately challenged by mandamus. That is precisely the kind of

piecemeal appellate review Texas law seeks to avoid. Prudential, 148

S.W.3d at 136. The Legislature could have authorized interlocutory

appeals for Business Court remand orders if it wished—but it did not.

See Tex. Gov’t Code Ch. 25A. That omission is deliberate. Courts should

not judicially create interlocutory review through mandamus where the

Legislature declined to do so.

Page 35 of 37
F. Summary.

This is not one of the rare, extraordinary cases that warrants

mandamus. The Business Court remand order involves an ordinary legal

question, subject to normal appellate correction, with no irreparable

harm. Mandamus should therefore be denied.

PRAYER

For the foregoing reasons, Real Party in Interest Jerry B. Reed

respectfully requests that the Court deny Relator’s Petition for Writ of

Mandamus.

DATED: October 9, 2025.

Respectfully submitted,
LAGARDE LAW FIRM, P.C.

/s/ Richard L. LaGarde
Richard L. LaGarde
State Bar No. 11819550
Mary LaGarde
State Bar No. 24037645
230 Westcott St., Suite 100
Houston, TX 77007
TEL: (713) 993-0660
richard@lagardelaw.com
mary@lagardelaw.com
ATTORNEYS FOR
REAL PARTY IN INTEREST

Page 36 of 37
CERTIFICATE OF SERVICE

I certify that, on October 9, 2025, a true and correct copy of the Response

of the Real Party in Interest to Relator’s Petition for Mandamus was

served on all counsel of record via the Court’s electronic-notification

system. The Honorable Melissa Andrews, Respondent, was served via

email to her court coordinator.

/s/ Richard LaGarde
Richard LaGarde

CERTIFICATE OF COMPLIANCE

This brief complies with the length limitations of TEX. R. APP. P.

9.4(i)(2)(B) because this brief consists of 6,097 words, excluding the parts

of the brief exempted by TEX. R. APP. P. 9.4(i)(1).

/s/ Richard LaGarde
Richard LaGarde

Page 37 of 37
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.

Richard LaGarde on behalf of Richard LaGarde
Bar No. 11819550
richard@lagardelaw.com
Envelope ID: 106683178
Filing Code Description: Original Proceeding Response
Filing Description: Real Person in Interest's Response to Petition for Writ
of Mandamus
Status as of 10/10/2025 7:02 AM CST

Case Contacts

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David Harrell 793905 david.harrell@troutman.com 10/9/2025 9:21:09 PM SENT

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Manfred Sternberg 19175775 manfred@msternberg.com 10/9/2025 9:21:09 PM SENT

Aimee Oleson 24036391 aoleson@sheppardmullin.com 10/9/2025 9:21:09 PM SENT

Mary Lagarde 24037645 mary@lagardelaw.com 10/9/2025 9:21:09 PM SENT

Jeffrey Adams 24006736 jeff@jeffadamslaw.com 10/9/2025 9:21:09 PM SENT

Jon Smith 18630750 jon@jonmichaelsmith.com 10/9/2025 9:21:09 PM SENT

Mia Lorick 24091415 Mia.Lorick@troutman.com 10/9/2025 9:21:09 PM SENT

Charles Conrad charles.conrad@pillsburylaw.com 10/9/2025 9:21:09 PM SENT

Grace Miller 24132499 gmiller@sheppardmullin.com 10/9/2025 9:21:09 PM SENT

Lindsey Mitchell lindsey.mitchell@pillsburylaw.com 10/9/2025 9:21:09 PM SENT

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Bradden Pippin 24143893 bradden.pippin@troutman.com 10/9/2025 9:21:09 PM SENT

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Jon Sink jonathan.sink@pillsburylaw.com 10/9/2025 9:21:09 PM SENT

Honorable Melissa Andrews bcdivision3a@txcourts.gov 10/9/2025 9:21:09 PM SENT

Ryan Dickinson ryandickinson79@gmail.com 10/9/2025 9:21:09 PM SENT