`22-0633
`12/6/2022 11:10 AM
`tex-70734347
`SUPREME COURT OF TEXAS
`BLAKE A. HAWTHORNE, CLERK
`
`
`
`
`
`December 6, 2022
`
`Via E-Filing
`
`Mr. Blake A. Hawthorne, Clerk
`Supreme Court of Texas
`201 West 14th Street, Room 104
`Austin, Texas 78701
`
`
`
`Re: No. 22-0633; Wirt Blaffer, Individually and Derivatively on Behalf of
`Freeport Waterfront Properties, L.P. v. Second Street Properties LLC,
`Briarwood Capital Corporation and H. Walker Royall, In the Supreme
`Court of Texas
`
`
`Dear Mr. Hawthorne:
`
`In accordance with Texas Rule of Appellate Procedure 53.3, Cross-
`Respondents Camilla Hrdy, Catherine Hrdy, Nicholas Hrdy, Katherine Taylor, and
`Christine Taylor respectfully submit this waiver of response to the conditional cross-
`petition for review filed by Cross-Petitioners Second Street Properties, LLC,
`Briarwood Capital Corporation, H. Walker Royal on November 7, 2022.
`
`Cross-Respondents will file a response to the conditional cross-petition for
`review should the Court request one.
`
`Respectfully submitted,
`
` /s/ Mark Trachtenberg
`Mark R. Trachtenberg
`State Bar No. 24008169
`mark.trachtenberg@haynesboone.com
`
`Counsel for Cross-Respondents Camilla Hrdy, Catherine Hrdy,
`Nicholas Hrdy, Katherine Taylor, and Christine Taylor
`
`
`
`
`
`
`
`
`
`
`
`Haynes and Boone, LLP
`
`1221 McKinney Street | Suite 4000 | Houston, TX 77010
`T: 713.547.2000 | haynesboone.com
`
`
`
`
`
`
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`
`
`CERTIFICATE OF SERVICE
`
`In accordance with the Texas Rules of Appellate Procedure I certify that a
`copy of this Waiver of Response was served on the following via e-service on
`December 6, 2022:
`
`Counsel for Petitioner Wirt Blaffer, Individually and Derivatively on Behalf of
`Freeport Waterfront Properties, L.P.:
`
`
`Alan B. Daughtry
`alan@alandaughtrylaw.com
`3535 West Alabama, Suite 444
`Houston, Texas 77098
`
`Counsel for Respondents/Cross-Petitioners Second Street Properties LLC,
`Briarwood Capital Corporation and H. Walker Royall:
`
`Chad Flores
`cflores@beckredden.com
`David J. Beck
`dbeck@beckredden.com
`John S. Adcock
`jadcock@beckredden.com
`Beck Redden LLP
`1221 McKinney, Suite 4500
`Houston, Texas 77010
`
`
`
`/s/ Mark Trachtenberg
`Mark Trachtenberg
`
`
`
`
`
`
`
`
`
`2
`
`
`
`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:
`Michelle Wenckens on behalf of Mark Trachtenberg
`Bar No. 24008169
`michelle.wenckens@haynesboone.com
`Envelope ID: 70734347
`Status as of 12/6/2022 11:17 AM CST
`
`Associated Case Party: Second Street Properties, LLC
`
`Name
`David J.Beck
`John S.Adcock
`
`BarNumber Email
`dbeck@beckredden.com
`jadcock@beckredden.com
`
`TimestampSubmitted
`12/6/2022 11:10:39 AM
`12/6/2022 11:10:39 AM
`
`Status
`SENT
`SENT
`
`Associated Case Party: Wirt Blaffer
`
`Name
`Alan Brandt Daughtry
`
`BarNumber
`793583
`
`alan@alandaughtrylaw.com
`
`TimestampSubmitted
`12/6/2022 11:10:39 AM
`
`Status
`SENT
`
`Case Contacts
`
`Name
`Charles Flores
`Mark Trachtenberg
`Ryan Pitts
`Michelle Wenckens
`
`BarNumber
`24059759
`
`cflores@beckredden.com
`mark.trachtenberg@haynesboone.com
`ryan.pitts@haynesboone.com
`michelle.wenckens@haynesboone.com
`
`TimestampSubmitted
`12/6/2022 11:10:39 AM
`12/6/2022 11:10:39 AM
`12/6/2022 11:10:39 AM
`12/6/2022 11:10:39 AM
`
`Status
`SENT
`SENT
`SENT
`SENT
`
`
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