IN THE UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

JONATHAN VILLAREAL, individually 

and derivatively on behalf of 

ZROBLACK, LLC. 

Plaintiffs, 

v. 

JOHN SAENZ, MIGUEL 

VILLARREAL, JR., and GUNN, LEE, 

& CAVE, P.C.

Defendants

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CIVIL ACTION NO. 5:20-cv-00571-OLG

PLAINTIFF’S REPLY TO DEFENDANT JOHN SAENZ’S RESPONSE IN 

OPPOSITION TO PLAINTIFF’S FIRST AMENDED APPLICATION FOR 

SEIZURE, TEMPORARY RESTRAINING ORDER, PRELIMINARY 

INJUNCTION, AND PERMANENT INJUNCTIVE RELIEF

________________________________________________________________________

Plaintiff JONATHAN VILLAREAL, individually and derivatively on behalf of 

ZROBLACK, LLC, (collectively the “Plaintiffs”), by and through its undersigned counsel, files 

this Plaintiff’s Reply to Defendant John Saenz’s Response in Opposition to Plaintiff’s First 

Amended Application for Seizure, Temporary Restraining Order, Preliminary Injunction, and 

Permanent Injunctive Relief and would respectfully show the Court as follows: 

I. INTRODUCTION

This dispute arises out of the business relationship between Plaintiff Jonathan 

Villarreal and Defendant John Saenz. Together, the pair formed Plaintiff ZroBlack, LLC, to market

software technology developed by Jonathan. The software in question is capable of wirelessly 

accessing cell phones and tablets and erasing or recovering data. After signing a contract with an 

overseas technology security company (the “Foreign Customer”), Saenz took $740,000 from 

ZroBlack and stopped doing work. Saenz and Villarreal negotiated a Release through Defendant 

Gun, Lee & Cave, P.C. Among other things, the Release called for Saenz to assign all his interest 

Case 5:20-cv-00571-OLG Document 44 Filed 02/25/21 Page 1 of 16
in ZroBlack to Jonathan. After the release was executed, Saenz refused requests to return a Mac 

laptop to ZroBlack. The laptop contained trade secrets, most notably the code, as well as access 

credentials to ZroBlack’s domain, www.zroblack.com, hosted by GoDaddy. Without access to the 

domain, ZroBlack could not update its credentials with Dun & Bradstreet, Apple, or government 

websites and agencies. This suit resulted.

Defendant Saenz now claims that he “purchased the Computer and has consistently 

used it since as his personal laptop computer.” (Doc. 42, p. 2). Saenz has also retained a third-party 

forensic analyst to inspect the computer. The analyst concluded “(1) the Computer does not contain 

any proprietary code, hardware schematics, or hardware drawings; (2) the Computer does not 

contain any non-factory-installed programming software; (3) the Computer does not contain any 

computer code, data or other trade secrets capable of performing ZroBlack's security services 

described in Plaintiff's Complaint and Application; and (4) there is no evidence or indication to 

suggest that any such code, data or other trade secrets have been deleted from the Computer.” 

(Doc. 42, p. 4; Doc. 42-1, p. 3).

The reason that this expert has not been able to find the proprietary code is because 

the numbers and letters that make up the code are saved in a text file on the laptop. The code is not 

engrained into the laptop, but there is character for character copies of the code language contained 

on that computer. Exhibit 45 (Declaration of Jonathan Villarreal). 

The proprietary code is stored in text files in the application Evernote,1a crossplatform note taking application similar to Windows “Notepad” or its more robust open-source 

1 https://evernote.com/

Case 5:20-cv-00571-OLG Document 44 Filed 02/25/21 Page 2 of 16
cousin “Notepad++.”2 Applications such as Evernote, Notepad, and Notepad++ are commonly 

used by programmers to edit raw source code.

The laptop was purchased on May 2, 2020. Exhibit 5 (Doc. 35-6). “TeamViewer” 

was used to access the laptop. TeamViewer is an application allows one to remotely access a 

computer over the Internet.

3 Exhibit 45. Jonathan remotely accessed the computer and uploaded 

the text files containing ZroBlack’s proprietary code to the Evernote application. The code was 

stored in a private folder in an Evernote file format. There were six files: “ABD Device ID,” “Clear 

MacOS iDevice Cached I/O,” “Samsung ID – AT Commands, ADB Commands, Validation, 

Partial Diagnostics, Logging,” LG Device ID – Analytics, Logging,” “Full Device ID & 

Diagnostics IOS,” and “OSI Full Hardware Diagnostics.” Because this code was stored in text 

files, the Saenz’s expert likely did not see it.

The code contained in the files performs the following:

ABD Device ID

This code is used to access Android devices remotely.

Clear MacOS iDevice Cached I/O

This code allows access to iPhones and iPads from a Mac and wirelessly to

clear the devices.

Samsung ID – AT Commands, ADB Commands, Validation, Partial 

Diagnostics, Logging

This code is used to perform forensics on Samsung Android devices.

LG Device ID – Analytics, Logging

This code is used to perform forensics on LG phones, tablets, and TVs 

running Android.

2 https://notepad-plus.org/

3 https://www.teamvewer.com/en-us/

Case 5:20-cv-00571-OLG Document 44 Filed 02/25/21 Page 3 of 16
Full Device ID and Diagnostics IOS

This code is used to perform forensics on IOS devices, both through a wired 

connection to the device and wirelessly.

IOS Full Hardware Diagnostics

This code is used to perform forensics for hardware chipsets on IOS devices

See Exhibit 45.

The Evenote text files are shown in Exhibit 42, which is an upload using Evernote’s 

WorkChat.

To utilize the code, the user copies and pastes the code from the corresponding 

Evernote file to the Mac laptop’s terminal command line (similar to the command prompt in 

Windows systems and command shell in Linux systems, which are text interfaces to the computer 

operating system) and then executes the code. Attached are Exhibits 43 and 44, which is a picture 

of Saenz taken at the Foreign Customer’s offices in Finland. Exhibit 44 is a magnified portion of 

Exhibit 43. In Exhibit 44, in the lower left-hand corner, the left-most icon shows a “dot” under it. 

The “dot” mean the application is open, and the icon is for the Mac’s terminal command line. The 

terminal command line was open because Saenz and Villarreal were using the laptop to 

demonstrate the code to the Foreign Customer, rebutting Saenz’s assertions that the laptop was for 

his personal use. Exhibit 45. In the picture, Saenz can be seen wearing his passport pouch around 

his neck, the power bar to the left of the laptop is for European plugs, and the bottled water, 

Novelle, is sold in Finland. Exhibit 43.

Case 5:20-cv-00571-OLG Document 44 Filed 02/25/21 Page 4 of 16
Furthermore, the hardware schematics to which Jonathan refers are attachments to 

the iMessage application installed on the laptop’s MacOS and are also attachments in Signal 

Messenger4and Mac mail, both of which are present on the laptop. Exhibit 45.

II. LEGAL STANDARD

A. Civil Seizure Standard

18 U.S.C. § 1836(b)(2)(A)(i) provides, in pertinent part, that a civil seizure may be 

granted upon ex parte application but only in extraordinary circumstances.5 The order may provide 

for the seizure of property that is necessary to prevent the propagation or dissemination of a trade 

secret, in this instance, the ZroBlack lap in Saenz’s possession and containing ZroBlack’s trade 

secrets.

Prior to issuing an ex parte seizure order, the court must find that:

i. An order issued pursuant to Rule 65 of the Federal Rules of Civil 

Procedure or another form of equitable relief is inadequate because the 

Defendant would evade, avoid, or otherwise not comply with such an 

order;

ii. Plaintiff has and will continue to suffer immediate and irreparable injury 

if seizure is not ordered; 

iii. The harm the Plaintiff of denying the application outweighs the harm to 

the legitimate interests of the Defendant and substantially outweighs the 

harm to any third parties who may be harmed by such seizure;

iv. Plaintiff is likely to succeed in showing that the information is a trade 

secret and the person against whom seizure would be ordered 

misappropriated the trade by improper means;

4 https://www.signal.org/

5 Plaintiffs recognize that ex parte may be a misnomer under these unusual circumstances. At 

the time the Complaint was filed, Plaintiffs were seeking a ex parte order. No ruling was issued

by the Court however, and Defendants quickly responded. Notwithstanding those facts, 

Plaintiffs believe seizure is appropriate under the factors set forth in the statute and discussed 

below.

Case 5:20-cv-00571-OLG Document 44 Filed 02/25/21 Page 5 of 16
v. The person against whom seizure would be ordered has actual possession 

of the trade secret and any property to be seized;

vi. Plaintiff can describe with reasonable particularity the matter to be seized 

and the location where the matter is to be seized;

vii. The person against whom seizure would be ordered may destroy, move, 

hide, or otherwise make such matter inaccessible to the court if Plaintiff 

were to proceed and notify Defendant; and

viii. Plaintiff has not publicized the requested seizure. 

18 U.S.C. § 1836(b)(2)(A)(ii).

B. Injunction Standard

A plaintiff seeking a preliminary injunction must establish that (1) it is likely to 

succeed on the merits, (2) it is likely to suffer irreparable harm in the absence of preliminary relief, 

(3) it has no adequate remedy at law, (4) the balance of equities tips in its favor, and (5) an 

injunction is in the public interest. Winter v. Natural Res. Def. Council, Inc., 555 U.S. 7, 20 (2008). 

“At the preliminary injunction stage, the procedures in district court are less formal, and the district

court may rely on otherwise inadmissible evidence, including hearsay evidence.” Sirius Computer 

Solutions, Inc. v. Sparks, 138 F. Supp. 3d 821, 836 (W.D. Tex. 2015).

III. ARGUMENT

A. The Motion to Dismiss SHOULD NOT BE GRANTED AS TO PLAINTIFF’S 

COMPLAINT AND APPLICATION

Pursuant to Federal Rule of Civil Procedure 10(c), Plaintiffs hereby incorporate by 

reference the arguments and premises set forth in the Plaintiff’s Response to Defendant John 

Saenz’s Second Rule 12(b)(6) Motion to Dismiss (Doc. 41) as if fully set forth herein and 

respectfully requests that Plaintiff's Application be granted for the reasons stated therein. 

Specifically, the Motion to Dismiss should be denied because the Release only releases claims that 

existed at the time the release was signed, not claims that arose or accrued in the future, and 

Case 5:20-cv-00571-OLG Document 44 Filed 02/25/21 Page 6 of 16
because Saenz has executory obligations under the Release that he has not fulfilled. The Court 

should also deny Defendant’s Motion because Plaintiffs’ have alleged facts on each of their causes 

of action as evidenced by the Plaintiffs’ Amended Complaint showing they are entitled to relief. 

B. The Application Should Not Be Denied Because Plaintiff Is Substantially 

Likely to Prevail on the Merits and There is a Substantial Threat of Irreparable 

Harm if the Injunction is not Granted

i. Plaintiffs met the pleading requirements for seizure

Saenz argues that Plaintiff’s Application for Seizure should be denied because 

Plaintiff “fails to show that an order pursuant to Federal Rule 65 would be inadequate” and that 

Plaintiff fails to show irreparable harm. (Doc. 42, p.6).

18 U.S.C. § 1836(b)(2)(A)(i) provides, in pertinent part, that a civil seizure may be 

granted upon ex parte application but only in extraordinary circumstances.6 The order may provide 

for the seizure of property that is necessary to prevent the propagation or dissemination of a trade 

secret, in this instance, the ZroBlack laptop in Saenz’s possession and containing ZroBlack’s trade 

secrets.

Prior to issuing an ex parte seizure order, the court must find that an order issued 

pursuant to Rule 65 of the Federal Rules of Civil Procedure or another form of equitable relief is 

inadequate because the Defendant would evade, avoid, or otherwise not comply with such an order

and Plaintiff has and will continue to suffer immediate and irreparable injury if seizure is not 

ordered. 18 U.S.C. § 1836(b)(2)(A)(ii).

6 Plaintiffs recognize that ex parte may be a misnomer under these unusual circumstances. At 

the time the Complaint was filed, Plaintiffs were seeking a ex parte order. No ruling was issued 

by the Court however, and Defendants quickly responded. Notwithstanding those facts, 

Plaintiffs believe seizure is appropriate under the factors set forth in the statute and discussed 

below.

Case 5:20-cv-00571-OLG Document 44 Filed 02/25/21 Page 7 of 16
Saenz argues that Plaintiff’s Application for Seizure should be denied because 

Plaintiff “fails to show that an order pursuant to Federal Rule 65 would be inadequate.” (Doc. 42, 

p.6).

ii. Plaintiff met the Rule 65 requirement

Saenz argues that Plaintiffs have to show why an order under Federal Rule of 

Procedure 65 would be inadequate. As a preliminary matter, Plaintiffs’ Rule 65(b)(1) certification 

is found in ¶¶ 66-70 of the Amended Application for Seizure, Temporary Restraining Order, and 

Temporary Injunction. (Doc. 37, p. 30-32), supported by the affidavit of Jonathan Villarreal, sets 

out the facts which clearly show that immediate and irreparable injury, loss, or damages will result 

to the movant before the adverse party can be heard in opposition. Furthermore, these paragraphs 

set forth the reasons why notice should not be required, namely the risk that Saenz will copy or 

destroy the trade secrets on the laptop computer. Plaintiffs’ also contend that counsel’s signature 

to the Complaint is enough to “certify” within the meaning of Rule 65.

Plaintiffs further showed why the ex parte order is necessary. Plaintiffs 

demonstrated that Saenz had already deleted emails, taken down ZroBlack’s website, and was 

refusing to return the laptop containing the trade secrets. These actions are enough to show a real 

risk of further destruction of information or misuse of the trade secrets. Finally, Plaintiffs also cited 

to federal case law holding that where a defendant could easily copy information from a computer, 

seizure was appropriate. See Blue Star Land Services v. Coleman, No. CIV-17-931-C, 2017 WL 

11309528, * 1 (W.D. Okla., Aug. 31, 2017). Thus, Plaintiffs met their burden of showing why 

Rule 65 relief would be inadequate.

iii. The twenty monthly delay is due primarily to Covid-19

Saenz also claimsthat a twenty-month delay is seeking seizure is evidence no actual 

or imminent harm is likely. What Saenz overlooks is that most of that delay is due to the CovidCase 5:20-cv-00571-OLG Document 44 Filed 02/25/21 Page 8 of 16
19 pandemic, circumstances beyond everyone’s control. The pandemic began affecting the United 

States in February 2020, with shutdowns beginning in March 2020. Texas Governor Greg Abbott 

declared a state of disaster on March 13, 2020, pursuant to Sections 418.014 and 418.016, and 

418.017 of the Texas Government Code.7 On the same day, the Texas Supreme Court and Texas 

Court of Criminal Appeals issued their First Emergency Order Regarding the Covid-19 State of 

Disaster.

8 The Western District of Texas, also on March 13, 2020, issued its Order Regarding 

Court Operations Under the Exigent Circumstances Created by the Covid-19 Pandemic.9

Texas has been under a state of disaster for nearly 12 months. That state of disaster 

has affected every citizen and business in the state, including plaintiffs, defendants, lawyers, and 

court staff. No one should be penalized for a 12-month delay that was entirely beyond anyone’s 

control. Additionally, as shown by the pleadings, Saenz, Jonathan, and ZroBlack parted ways in 

early August 2019, and Jonathan was occupied until at least the end of September of the same year 

trying to negotiate a return of the laptop. Thus, the delay in seeking relief was only eight months, 

half of which (February 2020 through May 2020) were at the beginning of the Covid-19 pandemic.

C. Plaintiffs met the pleading and evidentiary requirements for a temporary 

injunction

iv. Plaintiffs showed there was a substantial likelihood they would succeed on 

the merits

Plaintiffs extensively briefed likelihood of success on the merits in their 

Application, breaking down the elements of each claim for trade secret misappropriation, violation 

of the Computer Fraud and Abuse Act, Anti-Cybersquatting Consumer Protection Act, with 

7

https://gov.texas.gov/uploads/files/press/DISASTER_covid19_disaster_proclamation_IMAG

E_03-13-2020.pdf

8 https://www.txcourts.gov/media/1446056/209042.pdf

9 https://www.txwd.uscourts.gov/wp-content/uploads/2020/03/Order-Re-COVID-19.pdf

Case 5:20-cv-00571-OLG Document 44 Filed 02/25/21 Page 9 of 16
citation to documentary evidence provided in support. Plaintiffs need only present a prima facie 

case to show likelihood of success on the merits. Janvey v. Alguire, 647 F.3d 585, 505-596 (5th

Cir. 2011). Plaintiff has done so.

v. Proprietary code is present on the laptop, and Plaintiffs identified the 

code and sufficiently described it in the pleadings

Saenz first argues that Plaintiffs’ claims are based on a false premise that trade 

secrets are present on the laptop computer. This allegation is presumably based on their expert’s 

forensic examination of the laptop computer. With all due respect, their expert is mistaken because 

he does not understand the nature of Jonathan’s work or how the proprietary code is used.

The proprietary code is stored on the laptop as text files in Evernote.

The laptop was purchased on May 2, 2020. See Exhibit 5 (Doc. 35-6). Jonathan 

remotely accessed the computer and uploaded the text files containing ZroBlack’s proprietary 

code. The code is stored in a private folder in an Evernote file format. See Exhibit 45, attached 

hereto.

Saenz can still utilize or provide the code to others by copying the code from the 

corresponding Evernote file and send it to the highest bidder.

Furthermore, the hardware schematics to which Jonathan refers are attachments to 

the iMessage application installed on the laptop’s MacOS and are also attachments in Signal 

Messenger10 and Mac mail, both of which are present on the laptop. See Exhibit 45.

It is not the “ease of copying” that is the premise of Plaintiffs’ Application. It is 

what the proprietary code can do and what could happen if and when it falls into the wrong hands. 

Thus, Plaintiff’s have shown the “extraordinary circumstances” to warrant civil seizure. 

10 https://www.signal.org/

Case 5:20-cv-00571-OLG Document 44 Filed 02/25/21 Page 10 of 16
vi. The Inability to Access to the domain name and email server causes 

irreparable harm

Saenz mocks the Plaintiffs when he states, “the suggestion that ZroBlack-a 

company that is purportedly world-class in computer programming and remote device access-is 

now wholly unable to do business without a simple website and email subscription after 

approximately eighteen months without them is a complete fabrication.” (Doc. 42, p. 9). It is not 

just that Plaintiffs are unable to do business without a simple website and email subscription, it is 

also that the data and emails that have been lost and are currently under the control of Defendant. 

Plaintiff has made many attempts to remedy and fix the problems caused by access, he may have 

been able to remedy these damages if he had been given access. 

As alleged in the Amended Complaint, Jonathan sought the release of ZroBlack’s 

domain name information, from which he could himself update the Dun & Bradstreet information. 

Because Jonathan could not update ZroBlack’s DUNS information, he could not confirm to 

Apple’s satisfaction that he owned ZroBlack and so Apple refused him a developer’s account. 

Instead, Saenz refused Jonathan’s requests to release the ZroBlack domain name to 

him so that he could update ZroBlack’s information for Apple and Dun & Bradstreet. Saenz even 

went so far as to block Jonathan’s email address. 

ZroBlack has had to file complaints with the Federal Help Desk and Defense 

Logistics Agency because Saenz is effectively holding the SAM.gov login information and CAGE 

number hostage and has prevented ZroBlack from competing for government contracts. 

Plaintiffs have made it clear why access to the domain name and email server are 

necessary to the operation of ZroBlack as a business. Saenz has taken down the website. Saenz 

also deleted the email server, thereby destroying thousands of emails and documents supporting 

Jonathan’s claims, ZroBlack’s projects for Blancco, and other matters. Saenz currently holds 

Case 5:20-cv-00571-OLG Document 44 Filed 02/25/21 Page 11 of 16
ZroBlack’s domain name hostage, so Jonathan has no access to the site and no opportunity to 

attempt to recover the webpage and emails. GoDaddy is the service provider.

Courts have granted Preliminary Injunctions and ruled that there is a threat of 

irreparable harm, even if a domain is not active, when there is a possibility that “the domain name 

is transferred, leased, or sold to a party...the domain name may be reactivated and could cause 

confusion, mistake, and/or deceive consumers...”. Pace v. Constellation Brands, Inc., Civil Action 

No.: 4:17-cv-00518, 2017 WL 8811749 at *2-3 (E.D. Tex. Dec. 13, 2017). This misuse of the 

domain can cause harm by “disruption of ...business, loss of customer good will, and brand 

confusion.” Id. Furthermore, “if the domain name is transferred, leased, or sold to a third-party, 

they will be forced to take additional steps to obtain the domain name from a new owner, spurring 

additional litigation.” Id.

Irreparable harm has been found when a party it “not permitted to change its 

registration records, transfer the Domain Names, or otherwise monetize the names.” Domain 

Protection, LLC v. Sea Wasp, LLC, Civil Action No. 4:18-cv-792, 2019 WL 3219939 at *9 (E.D. 

Tex. Jul. 17, 2019). Courts have recognized that by preventing a party from updating the 

registration information affiliated with a domain name to reflect that it is no longer working with 

a party, but the emails affiliated with that domain are being directed to the party, the inability to

access the traffic data and emails, including business opportunities that may be time-sensitive, 

constitutes irreparable harm. Id. 

vii. Saenz has access to the server and domain

Saenz alleged that he “does not have access to any email “server.” (Doc. 42, p. 8).

Saenz’s own allegations prove the contrary. Saenz may not have access to any 

server, but he is the person who controls the access to it. Saenz states that he “purchased Microsoft 

365 Email Essentials from GoDaddy and added this email subscription to the zroblack.com domain 

Case 5:20-cv-00571-OLG Document 44 Filed 02/25/21 Page 12 of 16
under his existing GoDaddy account.” (Doc. 42, p. 8). Saenz goes on to state that he “created the 

zroblack.com domain...and added it to his existing GoDaddy account”. (Doc. 42, p. 8). It is clear 

from Saenz’s own sworn testimony that he controls the access to the server and domain linked to 

his GoDaddy account.

viii. Use of the trade secrets was alleged

Saenz argues that Jonathan and ZroBlack did not (1) define or adequately describe 

the proprietary code, (2) explain how or when the coded ended up on the Computer, (3) explain 

where the code is located or stored on the computer, or (4) explain what programs are required to 

use the code on the Computer. Plaintiffs are not aware, however, of any case law or rule that 

requires that degree of specificity. However, those details were disclosed, and are discussed above, 

and in Jonathan’s most recent declaration. See Exhibit 45. Finally, contrary to Saenz’s assertion 

paragraphs 7 and 8 of the Amended Application (Doc. 37) describes the software and explain what 

the software does.

ix. Irreparable harm was shown

Plaintiffs have alleged and shown that Saenz is in possession of trade secrets and 

in a position to use them. As explained in Plaintiffs’ Application, Defendants' prior actions 

demonstrate a willingness to evade or ignore the law. Daniel Health Sciences, L.L.C. v. Vascular 

Health Sciences, L.L.C., 710 F.3d 579, 585 (5th Cir. 2013). State law determines whether harm is 

irreparable. Heil Trailer Intern. Co. v. Kula, 542 Fed. Appx. 329, 336 (5th Cir. 2013). When a 

defendant is in possession of trade secrets and in a position to use them, state courts have presumed 

irreparable harm will result absent injunctive relief. Id. As observed by the Fifth Circuit in Heil 

Trailer, Texas courts have frequently found irreparable harm in such cases, further noting that the 

Fifth Circuit itself had upheld similar findings by federal district courts. Id. at 336 (and cases cited 

Case 5:20-cv-00571-OLG Document 44 Filed 02/25/21 Page 13 of 16
therein). Because Plaintiffs have shown that Saenz has previously destroyed ZroBlack’s data and 

is in possession of ZroBlack’s trade secrets, Plaintiffs have demonstrated irreparable harm.

IV. PRAYER

Based on the foregoing argument, Plaintiffs respectfully ask the Court to grant 

Plaintiffs the relief requested. Plaintiffs further pray for all such other relief to which they may 

show themselves justly entitled at law or in equity. 

Respectfully submitted,

THE VETHAN LAW FIRM, PC

By: /s/ Joseph L. Lanza

Charles M. R. Vethan 

Attorney-in-Charge

Texas Bar No. 00791852

Steven A. Costello

Texas Bar No. 24062677

VETHAN LAW FIRM - HOUSTON

Two Memorial City Plaza

820 Gessner, Suite 1510

Houston, Texas 77024

Tel: (713) 526-2222

Fax: (713) 526-2230

Email: edocs@vwtexlaw.com

Joseph L. Lanza

Texas bar No. 00784447

VETHAN LAW FIRM – SAN ANTONIO

11459 Huebner, Suite 101

San Antonio, Texas 78230

Tel: (210) 824-2220

Fax: (713) 526-2230

Email: edocs@vwtexlaw.com

Attorneys for Plaintiffs

Case 5:20-cv-00571-OLG Document 44 Filed 02/25/21 Page 14 of 16
CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing was electronically filed with the Court 

on the 25th day of February 2021, and electronically served on the date reflected in the 

ECF system upon all parties registered to receive notice pursuant to the Court’s CM/ECF 

system.

David A. Vanderhinder

State bar No. 24070787

DVanderhinder@dykema.com

Ryan J. Sullivan

State Bar No. 24102548

RSullivan@dykema.com

DYKEMA GOSSETT PLLC

112 East Pecan St., Suite 1800

San Antonio, Texas 78205

Attorney for Defendant John Saenz

George R. Spencer, Jr.

State Bar. No. 18921001

gspencer@langleybanack.com

Natalie F. Wilson

State Bar. No. 24067769

nwilson@langleybanack.com

Attorneys for Defendants Gunn, Lee & Cave, P.C.

And Miguel Villarreal, Jr.

/s/ Joseph L. Lanza

 Joseph L. Lanza

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