FORM NO.

353-3 - CITATION ESERVE

THE STATE OF TEXAS CITATION
To: JAVALE L MCGEE
8605 SANTA MONICA BLVD
DC-16-14156
LOS ANGELES CA 90069
GREETINGS:
You have been sued. You may employ an attorney. If you or your attorney do not file a written MATTHEW JOHNSON
answer with the clerk who issued this citation by 10 o'clock a.m. of the Monday next following the vs.
expiration of twenty days after you were served this citation and petition, a default judgment may be JAVALE MCGEE
taken against you. Your answer should be addressed to the clerk of the 101st District Court at 600
Commerce Street, Ste. 101, Dallas, Texas 75202.
ISSUED THIS
Said Plaintiff being MATTHEW T. JOHNSON 3rd day of November, 2016
Filed in said Court 1st day of November, 2016 against FELICIA PITRE
Clerk District Courts,
JAVALE L MCGEE Dallas County, Texas
For Suit, said suit being numbered DC-16-14156, the nature of which demand is as follows:
Suit on CNTR CNSMR COM DEBT etc. as shown on said petition, a copy of which accompanies this By: GAY LANE, Deputy
citation. If this citation is not served, it shall be returned unexecuted. ________________________________
WITNESS: FELICIA PITRE, Clerk of the District Courts of Dallas, County Texas. Attorney for Plaintiff
Given under my hand and the Seal of said Court at office this 3rd day of November, 2016. KEVIN M DUDDLESTON
2000 MCKINNEY AVENUE
ATTEST: FELICIA PITRE, Clerk of the District Courts of Dallas, County, Texas SUITE 1400
DALLAS TX 75201
By__________________________________, Deputy 214-932-6400
GAY LANE
 OFFICER'S RETURN
Case No. : DC-16-14156
Court No.101st District Court
Style: MATTHEW JOHNSON
vs.
JAVALE MCGEE
Came to hand on the ________________day of __________________, 20_________, at __________o'clock_________.M. Executed at ______________________________,
within the County of __________________________ at ____________ o'clock _______ .M. on the ________________day of_________________________________________,
20_______________, by delivering to the within named
____________________________________________________________________________________________________
____________________________________________________________________________________________________________
each, in person, a true copy of this Citation together with the accompanying copy of this pleading, having first endorsed on same date of delivery. The distance actually traveled by
me in serving such process was _________miles and my fees are as follows: To certify which witness my hand.
For serving Citation $__________ _______________________________________________
For mileage $__________ of__________________County, ____________________
For Notary $__________ By______________________________________Deputy
(Must be verified if served outside the State of Texas.)
Signed and sworn to by the said__________________________before me this_______day of _____________________, 20_______,
to certify which witness my hand and seal of office.
_____________________________________________________
Notary Public___________________County_________________
 FILED
DALLAS COUNTY
11/1/2016 2:03:08 PM
FELICIA PITRE
DISTRICT CLERK

Tonya Pointer
DC-16-14156
CAUSE NO. _____________

MATTHEW T. JOHNSON IN THE DISTRICT COURT OF

Plaintiff,

v. DALLAS COUNTY, TEXAS

JAVALE L. MCGEE,

Defendant. _____ JUDICIAL DISTRICT COURT

ORIGINAL PETITION

Plaintiff Matthew T. Johnson (Plaintiff), hereby files his Original Petition against JaVale

L. McGee (Defendant). In support thereof, Plaintiff respectfully shows the Court as follows:

I. Discovery

1. Plaintiff intends that discovery be conducted under a Level 3 discovery control

plan.

II. Parties

2. Plaintiff Matthew T. Johnson is an individual residing in Dallas County, Texas.

3. Upon information and belief, Defendant JaVale McGee is an individual residing in

Los Angeles, California and may be served with process at either 1888 Century Park East, Suite

1550 Los Angeles, California 90067 or 8605 Santa Monica Blvd., Los Angeles, California 90069.

III. Jurisdiction and Venue

4. This Court has jurisdiction over this lawsuit because Plaintiff is a Texas resident,

and Defendant entered into a contract with Plaintiff to be performed, in whole or in part, in Texas.

5. The amount in controversy in this lawsuit is within the jurisdictional limits of this

Court.
 6. Venue is proper in Dallas County because all or a substantial part of the events or

omissions giving rise to Plaintiffs claim occurred in Dallas County.

IV. Facts

A. The Lease

7. On September 12, 2015, Defendant entered into a residential lease agreement (the

Lease) with Plaintiff to lease the property located at 4439 N. Hall Street, Dallas, TX 75219

(Perry Heights BLK J/2048 LT 10), as well as the appliances and furnishings contained therein

(the Property), from September 16, 2015 to September 15, 2016.

8. Defendant paid Plaintiff a security deposit of $10,000.00.

9. The Lease provides that Plaintiff may deduct reasonable charges from the security

deposit for, among other things, damage to the Property, including reasonable costs associated

with repair of the Property.

10. The Lease further states that if deductions exceed the amount of the security

deposit, Defendant will pay Planitiff the excess amount within ten (10) days after Plaintiff makes

a written demand.

11. The Lease provides that Defendant pay Plaintiff a monthly rent in the amount of

$6,500.00 for each full month of the Lease.

12. Following the first month, each subsequent rent payment was due on the first day

of each month.

13. The Lease further provides that if Plaintiff did not receive the rent payment in the

full amount from Defendant by 11:59 PM on the third day of each month, Defendant would pay

Plaintiff an initial late charge of $50.00 and additional late charges of $50.00 per day thereafter

until the rent and late charges were paid in full.

PLAINTIFFS ORIGINAL PETITION Page 2

 14. The Lease also states that Defendant could not permit, even temporarily, any pet

on the Property.

15. If Defendant violated the prohibition against allowing a pet on the Property, the

Lease allowed Plaintiff the right to, among other actions, charge Defendant additional rent in an

initial amount of $500.00 and additional amounts of $50.00 per day per pet thereafter for each day

that Defendant violated the pet restriction.

16. The Lease provides that, if Defendant fails to timely pay all amounts due under the

Lease or otherwise fails to comply with the Lease, Defendant will be in default and, among other

consequences, Defendant will be liable for lost rent, repairs to the Property, costs incurred by

Plaintiff associated with the collection of amounts due under the Lease, and any other recovery to

which Plaintiff may be entitled by law.

B. Damage to the Property

17. During the lease term, Defendant caused significant damage to the Property,

including, but not limited to, damage to flooring, screen doors, area rugs, furniture, shelving, pots

and pans, a curtain rod, and a floor mat.

18. Further, when Defendant vacated the Property, various items were missing from

the Property, including, but not limited to, a showerhead, a closet handle, dishes, glasses, and

towels.

19. The damage to the Property exceeds the amount of the security deposit.

20. Plaintiff made a timely demand for payment of the amount required for repair and

replacement in excess of the security deposit, but Defendant has failed to pay the amount owed to

Plaintiff.

21. Plaintiff has had to incur the costs of repair and replacement personally.

PLAINTIFFS ORIGINAL PETITION Page 3

 22. Due to the damage to the Property caused by Defendant, Plaintiff sufferred lost

rental income during the period following the Lease term in which the Property was in an

unrentable state.

C. Unpaid Rent

23. Defendant failed to pay Plaintiff the final months prorated rent in the amount of

$3,250.00, which was due under the Lease no later than 11:59 PM on September 3, 2016.

24. Defendant requested that this final rent payment be deducted from the security

deposit.

25. Plaintiff did not agree to deduct the final rent payment from the security deposit.

26. Further, Plaintiff could not deduct the final rent payment from the secrity deposit

because the security deposit did not cover the costs incurred due to damage to the Property caused

by Defendant.

D. Late Rent Payments

27. Defendant was obligated under the Lease to pay Plaintiff rent in the amount of

$6,500.00 for the month of December 2015.

28. Under the Lease, the December 2015 rent payment was due to Plaintiff no later than

11:59 PM on December 3, 2015.

29. Defendant did not pay the full rent amount for December 2015 until December 8,

2015.

30. Defendant was obligated under the Lease to pay Plaintiff rent in the amount of

$3,250.00 for the period of September 1, 2016 to September 15, 2016.

31. Under the Lease, the rent payment for the period of September 1, 2016 to

September 15, 2016 was due to Plaintiff no later than 11:59 PM on September 3, 2016.

PLAINTIFFS ORIGINAL PETITION Page 4

 32. Defendant has yet to pay the full rent amount for the period of September 1, 2016

to September 15, 2016.

33. Plaintiff made a demand for the late rent payment fees owed to Plaintiff under the

Lease, but Defendant has failed to pay the fees owed to Plaintiff.

E. Pet Restriction Violation

34. In violation of the Lease, Defendant allowed a cat to reside on the Property during

the term of the Lease.

35. The cat resided on the Property for at least 178 days during the term of the Lease.

36. Plaintiff made a demand for the additional rent and fees owed to Plaintiff under the

Lease for Defendants violation of the pet restriction, but Defendant has failed to pay the additional

rent and fees owed to Plaintiff.

V. Cause of Action

Breach of Contract

37. Plaintiff re-alleges and incorporates by reference the facts set forth in Paragraphs

1-36 above. Plaintiff and Defendant entered into the Lease, which is a valid, binding contract.

Plaintiff performed according to the terms of the Lease. Defendant breached the Lease by failing

to make rent payments, making untimely rent payments, violating the pet restriction, and failing

to compensate Plaintiff for the damage caused to the Property in excess of the value of the security

deposit. Plaintiff has sustained damages as a result of Defendants breach of the Lease.

VI. Request For Attorneys Fees

38. Due to Defendants breach of the Lease, it became necessary for Plaintiff to retain

the undersigned counsel in order to collect those sums. Plaintiff has agreed to pay his counsel

reasonable and necessary fees in undertaking that task. The above-referenced Lease is a valid,

binding contract. Plaintiff has properly presented his claims to Defendant, and Defendant has failed

PLAINTIFFS ORIGINAL PETITION Page 5

to honor his obligations. Therefore, Plaintiff seeks recovery of his attorneys fees, pursuant to

Chapter 38 of the Texas Civil Practice and Remedies Code. Plaintiff asks that the Court award him

the reasonable and necessary attorneys fees incurred in obtaining the judgment referenced in this

Petition.

39. Plaintiff also seeks attorneys fees and costs pursuant to the Lease, which provides

that a prevailing party in any legal proceeding brought under or related to the transaction described

in the Lease is entitled to such fees and costs.

VII. Conditions Precedent.

40. Plaintiff, in accordance with Rule 54 of the Texas Rules of Civil Procedure, avers

that all conditions precedent have been performed or have occurred.

VIII. Prayer for Relief.

41. WHEREFORE, Plaintiff prays that Defendant be cited to appear and answer herein,

and that upon hearing thereof, the Court:

a. enter judgment against Defendant in favor of Plaintiff for all damages

suffered by Plaintiff due to Defendants breach of the Lease, plus interest

accrued through the date of judgment;

b. award Plaintiff his attorneys fees in pursuing the foregoing claims; and

c. award Plaintiff all other relief to which he is justly entitled, at law or in

equity, including costs of court.

PLAINTIFFS ORIGINAL PETITION Page 6

 Respectfully submitted,

MCGUIREWOODS, LLP

By:
Kevin M. Duddlesten
Texas Bar No. 00793644
kduddlesten@mcguirewoods.com
Jacob A. Lewis
Texas Bar No. 24087924
jlewis@mcguirewoods.com
2000 McKinney Avenue, Suite 1400
Dallas, Texas 75201
Telephone: 214.932.6400
Facsimile: 214.273.6499

ATTORNEYS FOR PLAINTIFF

PLAINTIFFS ORIGINAL PETITION Page 7

 CAUSE NO. DC-16-14156

MATTHEW T. JOHNSON IN THE DISTRICT COURT OF

Plaintiff,

v. DALLAS COUNTY, TEXAS

JaVale L. McGee,

Defendant. 101ST JUDICIAL DISTRICT COURT

PLAINTIFFS REQUEST FOR DISCLOSURE TO DEFENDANT

TO: Defendant, JaVale McGee, 1888 Century Park East, Suite 1550 Los Angeles, CA 90067;
8605 Santa Monica Blvd., Los Angeles, CA 90069; bigdaddywookie@me.com.

Pursuant to Texas Rule of Civil Procedure 194, Plaintiff Matthew T. Johnson requests

that you disclose, within 30 days of service of this request, the information or material described

in Texas Rule of Civil Procedure 194.2:

(a) the correct names of the parties to the lawsuit;

(b) the name, address, and telephone number of any potential parties;

(c) the legal theories and, in general, the factual bases of the responding partys

claims or defenses;

(d) the amount and any method of calculating economic damages;

(e) the name, address, and telephone number of persons having knowledge of

relevant facts, and a brief statement of each identified persons connection with

the case;

(f) for any testifying expert:

(1) the experts name, address, and telephone number;

(2) the subject matter on which the expert will testify;

1
 (3) the general substance of the experts mental impressions and opinions and

a brief summary of the basis for them, or if the expert is not retained by,

employed by, or otherwise subject to the control of the responding party,

documents reflecting such information;

(4) if the expert is retained by, employed by, or otherwise subject to the

control of the responding party:

(A) all documents, tangible things, reports, models, or data

compilations that have been provided to, reviewed by, or prepared

by or for the expert in anticipation of the experts testimony; and

(B) the experts current resume and bibliography;

(g) any indemnity and insuring agreements described in Rule 192.3(f);

(h) any settlement agreements described in Rule 192.3(g);

(i) any witness statements described in Rule 192.3(h);

(j) in a suit alleging physical or mental injury and damages from the occurrence that

is the subject of the case, all medical records and bills that are reasonably related

to the injuries or damages asserted or, in lieu thereof, an authorization permitting

the disclosure of such medical records and bills;

(k) in a suit alleging physical or mental injury and damages from the occurrence that

is the subject of the case, all medical records and bills obtained by the responding

party by virtue of an authorization furnished by the requesting party;

(l) the name, address, and telephone number of any person who may be designated as

a responsible third party.

2
Dated: November 4, 2016 Respectfully submitted,

/s/ Kevin M. Duddlesten

Kevin M. Duddlesten
Texas Bar No. 00793644
kduddlesten@mcguirewoods.com
Jacob A. Lewis
Texas Bar No. 24087924
jlewis@mcguirewoods.com
McGuireWoods LLP
2000 McKinney, Suite 1400
Dallas, TX 75201
Telephone: 214.932.6400
Facsimile: 214.932.6499

ATTORNEYS FOR PLAINTIFF

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the above and foregoing has been served
in accordance with Rule 501.4 of the Texas Rules of Civil Procedure on November 4, 2016, as
follows:

JaVale McGee
1888 Century Park East
Suite 1550
Los Angeles, CA 90067

8605 Santa Monica Blvd.

Los Angeles, CA 90069

bigdaddywookie@me.com

/s/ Kevin M. Duddlesten

Kevin M. Duddlesten

3
 CAUSE NO. DC-16-14156

MATTHEW T. JOHNSON IN THE DISTRICT COURT OF

Plaintiff,

v. DALLAS COUNTY, TEXAS

JaVale L. McGee,

Defendant. 101ST JUDICIAL DISTRICT COURT

PLAINTIFFS FIRST SET OF REQUESTS FOR ADMISSIONS TO DEFENDANT

TO: Defendant, JaVale McGee, 1888 Century Park East, Suite 1550 Los Angeles, CA 90067;
8605 Santa Monica Blvd., Los Angeles, CA 90069; bigdaddywookie@me.com.

Pursuant to Rule 197 of the Texas Rules of Civil Procedure, Plaintiff Matthew T. Johnson

serves these first set of requests for admission to Defendant JaVale L. McGee.

DEFINITIONS AND INSTRUCTIONS

In the event of any conflict or ambiguity between the following definitions, common usage
and reference to any cited rules, statutes, or regulations should be used to provide the broadest
interpretation of the term in question.

A. As used in this document, the terms Defendant, McGee, you, or your

means Defendant JaVale L. McGee and shall include all persons acting or purporting to act on his
behalf.

B. As used in this document, the terms Plaintiff or Johnson means Plaintiff

Matthew Johnson and shall include all persons acting on his behalf.

C. Petition or Lawsuit refers to Plaintiffs petition filed in the case styled Matthew
Johnson v. JaVale L. McGee, in the District Court of Dallas County, TX, and shall include any and
all subsequent amendments or supplements thereto.

D. The term Lease means the residential lease agreement entered into between you
and Plaintiff to lease the property located at 4439 N. Hall Street, Dallas, TX 75219 and the
appliances and furnishings contained therein from September 16, 2015 to September 15, 2016.

E. The term Property means the property located at 4439 N. Hall Street, Dallas, TX
75219 and the appliances and furnishings contained therein.

F. The masculine gender as used herein includes the feminine and neuter genders.

1
 TIME PERIOD

G. Unless otherwise stated, each Request covers the entire time period from September
1, 2015 through the time of trial (hereinafter referred to as the Period). Each Request, whether
expressed in the present tense or otherwise, refers to the entire Period.

DUTY TO SUPPLEMENT

H. Each of the following Requests is a continuing one. If you later obtain, or become
aware of, any further information pertaining to these Requests, you are requested to serve upon
Defendant amended responses setting forth such information.

CONFERENCE BETWEEN COUNSEL

I. Defendant request that counsel for the responding party confer with counsel for all
parties affected by a discovery request and make a reasonable effort to resolve any discovery
disputes prior to filing a motion or seeking court intervention regarding any discovery request or
objection submitted.

INSTRUCTIONS

A. Please respond to each Request by specifically and truthfully admitting or denying

all portions of the matter contained therein.

B. Each such Request shall be deemed admitted unless Plaintiff serves the undersigned
counsel with a written denial or objection thereto.

C. Each answer, if not admitted, shall specifically deny the matter or set forth in detail
the reasons why you cannot truthfully admit or deny the matter.

D. If, in good faith, you must qualify your answer or deny only a part of the matter of
which an admission is requested, you must specify so much of it as is true and qualify or deny the
remainder.

E. You may not give lack of information or knowledge as a reason for failure to admit
or deny unless you state that you have made a reasonable inquiry and that the information known
or readily obtainable by you is insufficient to enable you to admit or deny the Request or any portion
thereof.

F. You may not object to any Request solely on the grounds that you consider the
matter to present an issue for trial.

G. If you fail to admit or deny any portion of a Request on the grounds that an admission
or denial would reveal privileged information, or is otherwise excludable from discovery, please
identify the information, describe its subject matter, and specify the basis for the claimed privilege
or other grounds of exclusion.

2
 REQUESTS FOR ADMISSION

REQUEST FOR ADMISSION NO. 1: Admit that the Lease attached hereto as Exhibit A is a
true and correct copy of the residential lease agreement between you and Plaintiff to lease the
Property.

RESPONSE:

REQUEST FOR ADMISSION NO. 2: Admit that the Lease is a valid, binding contract.

RESPONSE:

REQUEST FOR ADMISSION NO. 3: Admit that the Lease provides that Plaintiff may deduct
reasonable charges from the security deposit for, among other things, damage to the Property,
including reasonable costs associated with repair of the Property.

RESPONSE:

REQUEST FOR ADMISSION NO. 4: Admit that the Lease provides that if the reasonable
charges deducted from the security deposit exceeds the amount of the security deposit, you agree
to pay Plaintiff the excess amount within 10 days after Plaintiff makes a written demand.

RESPONSE:

REQUEST FOR ADMISSION NO. 5: Admit that Plaintiff made a demand for the amount of
deductions from the security deposit in excess of the amount of the security deposit by letter dated
October 13, 2016.

RESPONSE:

REQUEST FOR ADMISSION NO. 6: Admit that you did not pay to Plaintiff the amount of
deductions from the security deposit in excess of the amount of the security deposit.

RESPONSE:

3
REQUEST FOR ADMISSION NO. 7: Admit that the Lease provides that, during the term of the
Lease, you will pay Plaintiff a monthly rent in the amount of $6,500.00 for each full month of the
Lease.

RESPONSE:

REQUEST FOR ADMISSION NO. 8: Admit that the Lease provides that, following the first
month of the Lease, each subsequent rent payment was due on the first day of each month.

RESPONSE:

REQUEST FOR ADMISSION NO. 9: Admit that the Lease provides that if Plaintiff did not
receive the rent payment in the full amount from you by 11:59 PM on the third day of each month,
you would pay Plaintiff an initial late charge of $50.00 and additional late charges of $50.00 per
day thereafter until the rent and late charges were paid in full.

RESPONSE:

REQUEST FOR ADMISSION NO. 10: Admit that the Lease provides that you would not permit,
even temporarily, any pet on the Property.

RESPONSE:

REQUEST FOR ADMISSION NO. 11: Admit that the Lease provides that if you violated the
prohibition against allowing a pet on the Property, Plaintiff retained the right to charge you
additional rent in an initial amount of $500.00 and additional amounts of $50.00 per day per pet
thereafter for each day that you allowed a pet on the Property.

RESPONSE:

REQUEST FOR ADMISSION NO. 12: Admit that the Lease provides that, if you failed to timely
pay all amounts due under the Lease, you would be in default.

RESPONSE:

REQUEST FOR ADMISSION NO. 13: Admit that the Lease provides that, in the event you
defaulted on the Lease, you would be liable for lost rent, repairs to the Property, costs incurred by

4
Plaintiff associated with the collection of amounts due under the Lease, and any other recovery to
which Plaintiff may be entitled by law.

RESPONSE:

REQUEST FOR ADMISSION NO. 14: Admit that, during the term of the Lease, you caused
damage to the Property.

RESPONSE:

REQUEST FOR ADMISSION NO. 15: Admit that the damage you caused to the Property cost
Plaintiff at least $12,050.30 to remedy.

RESPONSE:

REQUEST FOR ADMISSION NO. 16: Admit that, following the end of the Lease, the Property
was in an unrentable state due to the damage you caused to the Property.

RESPONSE:

REQUEST FOR ADMISSION NO. 17: Admit that, due to the damage you caused to the
Property, Plaintiff could not rent the Property to another tenant from September 16, 2016 until
December 1, 2016.

RESPONSE:

REQUEST FOR ADMISSION NO. 18: Admit that, due to the damage you caused to the
Property, Plaintiff suffered lost rental income for the period from September 16, 2016 until
December 1, 2016.

RESPONSE:

REQUEST FOR ADMISSION NO. 19: Admit that you failed to pay the final months rent owed
under the Lease.

RESPONSE:

5
REQUEST FOR ADMISSION NO. 20: Admit that the final months rent owed under the Lease
was a prorated amount of $3,250.00.

RESPONSE:

REQUEST FOR ADMISSION NO. 21: Admit that you instructed Plaintiff to deduct the final
months rent payment from the security deposit.

RESPONSE:

REQUEST FOR ADMISSION NO. 22: Admit that Plaintiff did not agree to deduct the final
months rent payment from the security deposit.

RESPONSE:

REQUEST FOR ADMISSION NO. 23: Admit that you did not pay the full rent amount owed
under the lease for December 2015 until December 8, 2015.

RESPONSE:

REQUEST FOR ADMISSION NO. 24: Admit that Plaintiff made a written demand for late
rental payment fees owed to Plaintiff under the Lease.

RESPONSE:

REQUEST FOR ADMISSION NO. 25: Admit that you have not paid Plaintiff the late rental
payment fees owed to Plaintiff under the Lease.

RESPONSE:

REQUEST FOR ADMISSION NO. 26: Admit that you owe Plaintiff $850.00 for late rental
payment fees due to Plaintiff under the Lease.

RESPONSE:

6
REQUEST FOR ADMISSION NO. 27: Admit that you allowed a cat on the Property during the
term of the Lease.

RESPONSE:

REQUEST FOR ADMISSION NO. 28: Admit that you allowed a cat on the Property for at least
178 days during the term of the Lease.

RESPONSE:

REQUEST FOR ADMISSION NO. 29: Admit that Plaintiff made a written demand for the
additional rent and fees owed to Plaintiff under the Lease due to your violation of the Leases pet
restriction.

RESPONSE:

REQUEST FOR ADMISSION NO. 30: Admit that you have not paid Plaintiff the additional rent
and fees owed Plaintiff under the Lease due to your violation of the Leases pet restriction.

RESPONSE:

REQUEST FOR ADMISSION NO. 31: Admit that you owe Plaintiff $9,350.00 for the additional
rent and fees due to Plaintiff under the Lease for your violation of the Leases pet restriction.

RESPONSE:

7
Dated: November 4, 2016 Respectfully submitted,

/s/ Kevin M. Duddlesten

Kevin M. Duddlesten
Texas Bar No. 00793644
kduddlesten@mcguirewoods.com
Jacob A. Lewis
Texas Bar No. 24087924
jlewis@mcguirewoods.com
2000 McKinney Avenue, Suite 1400
Dallas, Texas 75201
Telephone: 214.932.6400
Facsimile: 214.273.6499

ATTORNEYS FOR PLAINTIFF

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the above and foregoing has been served in
accordance with Rule 501.4 of the Texas Rules of Civil Procedure on November 4, 2016, as follows:

JaVale McGee
1888 Century Park East
Suite 1550
Los Angeles, CA 90067

8605 Santa Monica Blvd.

Los Angeles, CA 90069

bigdaddywookie@me.com

/s/ Kevin M. Duddlesten

Kevin M. Duddlesten