FILED: 5/24/2023 8:14 AM

David Trantham
Denton County District Clerk
By: Maribel Villarreal, Deputy

NOTICE: THIS DOCUMENT

CONTAINS SENSITIVE DATA

CAUSE NO. 21-6023-367

IN THE MATTER OF THE § IN THE DISTRICT COURT

MARRIAGE OF §
§
S L.G. § 367TH JUDICIAL DISTRICT
AND §
J.P.G. § DENTON COUNTY, TEXAS

PETITIONER’S RESPONSE TO INTERVENOR’S MOTION TO CONSOLIDATE

COMES NOW, Petitioner, Sherry L. Green, and files her Response to Intervenor’s Motion

to Consolidate and for same would state as follows:

Consolidation is unnecessary, particularly, when the corporations are different entities.

Consolidation will only serve to complicate and delay the pending litigation.

Additionally, Consolidation is unnecessary when an attorney has not received the

authority from their client to file a Motion to Consolidate. Based upon an e-mail written by JR

Johnson, attorney for Defendant, Jame Green in Cause No. 22-9806-431 on or about May 9, 2023,

Intervenor “did not copy [him] in [his] role in the FFMB case.” Further, Mr. Johnson states “I am

receiving email traffic stating that [Intervenor has] filed Motions to Consolidate and one [from

Respondent] stating no objections” and then has to the request that documents be sent to him. A

true and correct copy of the May 9, 2023 e-mail from JR Johnson is attached hereto and

incorporated herein as Exhibit A.

More importantly, in Mr. Johnson’s email, he states, “[f]urther, and most importantly, my

client was unaware of your motions.” Counsel for Intervenor did not have the authority of its client,

A#1 Air, Inc. to file the Motion to Consolidate nor did counsel for Respondent, James P. Green

have the authority from their client to file Counter-Petitioner/Respondent’s Notice of Non-

PETITIONER’S RESPONSE TO INTERVENOR’S MOTION TO CONSOLIDATE Page 1 of 4

Opposition to Intervenor’s Motion to Consolidate.

Furthermore, Mr. Johnson states in his email that “[i]n fact, James Green has issued me, in

writing, instruction stating his desire that I cease all legal activity during this period of settlement

negotiations” and advises that “[d]uring a phone conference this morning, [James Green] stated he

had relayed those same terms to you as well. Given that the client does not wish for any

motions/legal matters to be heard at present, I object . . . and ask that you notify the court of same.”

Additionally, the Motion to Consolidate filed by Intervenor, A#1 Air, Inc., should have

included notice to Roger Yale, the attorney for Plaintiff, Sherry L. Green, Individually and on

behalf of FFMB GP LLC, and FFMB Ltd, and to JR Johnson, the attorney for James P. Green. As

stated above, James P. Green did not authorize the filing of a Motion to Consolidate by Intervenor.

For these reasons, Petitioner, Sherry L. Green respectfully requests this Court to deny the

Motion to Consolidate by Intervenor, A#1 Air, Inc.

Prayer

For the reasons set forth above, Petitioner, Sherry L. Green respectfully request the Court

deny Intervenor’s Motion to Consolidate in this matter and for such other and further relief for

which the Petitioner may show herself to be justly entitled.

PETITIONER’S RESPONSE TO INTERVENOR’S MOTION TO CONSOLIDATE Page 2 of 4

 Respectfully submitted,

The Lynch Law Firm

By: /s/ Jeffrey S. Lynch

Jeffrey S. Lynch
Texas Bar No. 12727500
lynch@lynchlawfirm.law

5922 Mapleshade Lane

Dallas, Texas 75252
Tel. (972) 991-0000
Fax (972) 848-4076

ATTORNEYS FOR PETITIONER,

SHERRY L. GREEN

PETITIONER’S RESPONSE TO INTERVENOR’S MOTION TO CONSOLIDATE Page 3 of 4

 CERTIFICATE OF SERVICE

I certify that on May 24, 2023, a true and correct copy of the foregoing was served by email
in accordance with the Texas Rules of Civil Procedure on Laura B. Roach, McCathern, PLLC, One
Cowboys Way, Suite 175, Frisco, Texas 75034, George Parker, Verner Brumley Mueller Parker, 205
Louisiana Street, Suite 100, McKinney, Texas 75219 and Richard Hayes, Hayes, Berry, White &
Vanzant, LLP, 512 West Hickory, Suite 100, Denton, Texas 76201.

Jeffrey S. Lynch

PETITIONER’S RESPONSE TO INTERVENOR’S MOTION TO CONSOLIDATE Page 4 of 4

 Jeff Lynch <lynch@lynchlawfirm.law>

Motion to Consolidate
J.R. Johnson <jr@bjlattorneys.com> Tue, May 9, 2023 at 12:38 PM
To: Richard Hayes <Rhayes@hbwvlaw.com>, Jeff Lynch <lynch@lynchlawfirm.law>, David Kruger
<dkruger@hbwvlaw.com>, Kenneth Ferguson <kferguson@hbwvlaw.com>, Roger Yale <roger@yalelawgroup.com>

Gentlemen:

I am receiving email traffic stating that you have filed Motions to Consolidate and one stating no objections. However,
as I am not involved in the original divorce/intervenor’s case, and you did not copy me in my role in the FFMB case, I
am asking that you send me those documents.

Further, and most importantly, my client was unaware of your motions. In fact, James Green has issued me, in
writing, instructions stating his desire that I cease all legal activity during this period of settlement negotiations. During
a phone conference this morning, he stated he had relayed those same terms to you as well. Given that the client
does not wish for any motions/legal matters to be heard at present, I object to any of those proposed dates and ask
that you notify the court of same.

Please contact me if you have any questions.

Sincerely,

J.R. Johnson
BAILEY, JOHNSON & LYON, PLLC
Attorney
214.914.9993
jr@bjlattorneys.com

EXHIBIT A
 NOTICE: PRIVILEGED AND CONFIDENTIAL

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 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.

Jeffrey Lynch
Bar No. 12727500
lynch@lynchlawfirm.law
Envelope ID: 75941338
Filing Code Description: Response
Filing Description: to Intervenor's Motion to Consolidate
Status as of 5/24/2023 9:16 AM CST

Associated Case Party: A#1 Air, Inc.

Name BarNumber Email TimestampSubmitted Status

Richard DHayes rhayes@hbwvlaw.com 5/24/2023 8:14:18 AM SENT

L. Pittman lpittman@hbwvlaw.com 5/24/2023 8:14:18 AM SENT

Associated Case Party: SherryLGreen

Name BarNumber Email TimestampSubmitted Status

Craig A. Jackson 797925 craig@cjlawoffice.com 5/24/2023 8:14:18 AM SENT

Sean Abeyta sean@koonsfuller.com 5/24/2023 8:14:18 AM SENT

Charla H.Bradshaw charla@koonsfuller.com 5/24/2023 8:14:18 AM SENT

Elaine Sanders esanders@koonsfuller.com 5/24/2023 8:14:18 AM SENT

Kim Steward ksteward@koonsfuller.com 5/24/2023 8:14:18 AM SENT

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Laura Bohlman Roach 796223 lroach@mccathernlaw.com 5/24/2023 8:14:18 AM SENT

Jeffrey Lynch lynch@lynchlawfirm.law 5/24/2023 8:14:18 AM SENT

Beth Holland beth@lynchlawfirm.law 5/24/2023 8:14:18 AM SENT

David Kruger dkruger@hbwvlaw.com 5/24/2023 8:14:18 AM SENT

Kenneth Ferguson kferguson@hbwvlaw.com 5/24/2023 8:14:18 AM SENT

Roger M. Yale 789959 roger@yalelawgroup.com 5/24/2023 8:14:18 AM SENT

James Johnson 24084650 jr@bjlattorneys.com 5/24/2023 8:14:18 AM SENT

Associated Case Party: JamesPGreen

 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.

Jeffrey Lynch
Bar No. 12727500
lynch@lynchlawfirm.law
Envelope ID: 75941338
Filing Code Description: Response
Filing Description: to Intervenor's Motion to Consolidate
Status as of 5/24/2023 9:16 AM CST

Associated Case Party: JamesPGreen

Name BarNumber Email TimestampSubmitted Status

Michael P.Ricchi mricchi@mccathernlaw.com 5/24/2023 8:14:18 AM SENT

Erin Clegg eclegg@mccathernlaw.com 5/24/2023 8:14:18 AM SENT

George Parker firm@vernerbrumley.com 5/24/2023 8:14:18 AM SENT

Julie Markham jmarkham@vernerbrumley.com 5/24/2023 8:14:18 AM SENT

Jamie Laird jlaird@mccathernlaw.com 5/24/2023 8:14:18 AM SENT

Ravi VMohan rmohan@vernerbrumley.com 5/24/2023 8:14:18 AM SENT

George Parker gparker@vernerbrumley.com 5/24/2023 8:14:18 AM SENT