4:22-cv-00359-O Motion for Entry of Default Judgment against Eulises and Gilberto Gonzalez 1 of 3

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF TEXAS – FORT WORTH DIVISION

TONY JONES

 Plaintiff,

v.

CITY OF FORT WORTH, 

EULISES GONZALEZ, and 

GILBERTO GONZALEZ.

 Defendants.

§

§

§

§

§

§

§

§

§

 4:22-cv-00359-O

______________________________________________________________________________

PLAINTIFF’S MOTION FOR ENTRY OF DEFAULT JUDGMENT

TO THE HONORABLE COURT:

Pursuant to Fed. R. Civ. P. 55, Plaintiff Tony Jones moves this Court for a default final 

judgment as to defendants Eulises Gonzalez and Gilberto Gonzalez (“Defendants”), and in support 

thereof shows the Court the following:

1. On April 19, 2022, Plaintiff filed a complaint against Defendants and the City of Fort 

Worth. The case was given cause number 048-333132-22 and assigned to the 48th District Court.

2. On April 25, 2022, the City of Fort Worth removed this action to the present Court, based 

on the federal claims concerning due process alleged by Plaintiff and 28 U.S.C. § 1446. 

3. Following service to Defendants, their failure to respond, and the September 28, 2022 entry 

of default (Doc. 15), Defendants have filed no response; default judgment remains appropriate 

against these parties. Fed. R. Civ. P. 55(a) and (b)(2).

4. To ensure clarity, Defendants are not in military service, making inapplicable the 

Servicemembers' Civil Relief Act (55 U.S.C. app. §521(b)(1)). See supporting affidavits attached 

as Exhibit 1 (Eulises Gonzalez) and Exhibit 2 (Gilberto Gonzalez). 

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 1 of 35 PageID 311
4:22-cv-00359-O Motion for Entry of Default Judgment against Eulises and Gilberto Gonzalez 2 of 3

5. Plaintiff seeks damages for the following causes and amounts, established by the attached 

Declaration of Tony Jones, Exhibit 3. 

a. Per Se Defamation in the amount of $25,000,

b. Trespass to Real Property in the amount of $1000,

c. Trespass to Personal Property in the amount of $100,000,

d. Intentional Infliction of Emotional Distress in the amount of $250,000.

6. Plaintiff also requests attorney fees regarding his claim for Per Se Defamation, in the 

amount of $1,919.50, which have been segregated to reflect only that claim, as proved in the 

Declaration of Warren V. Norred, Exh. 4.

7. As the claims against the City of Fort Worth have been dismissed and by the direction of 

the Court, Plaintiff now moves the Court to certify the default judgment as a final judgment under 

Fed. R. Civ. P. 55(b)(2) and award damages as described. 

WHEREFORE, Plaintiff prays the Court enter default judgment against Eulises Gonzalez 

and Gilberto Gonzalez, for economic damages in the amount of $376,000, attorney fees in the 

amount of $1,919.50 and all other remedies as appropriate. 

Submitted on January 12, 2023,

/s/ Warren V. Norred

Warren V. Norred; State Bar No. 24045094; warren@norredlaw.com

NORRED LAW, PLLC

515 E. Border St.; Arlington, TX 76010

(817) 704-3984 / (817) 524-6686

Attorney for Plaintiff

Attached Exhibits:

1 – Affidavit regarding Eulises Gonzalez 

2 – Affidavit regarding Gilberto Gonzalez 

3 – Declaration of Tony Jones

4 – Declaration of Warren V. Norred (including 4a – Case Time Report)

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 2 of 35 PageID 312
4:22-cv-00359-O Motion for Entry of Default Judgment against Eulises and Gilberto Gonzalez 3 of 3

Certificate of Service: I hereby certify that on January 12, 2023, a true and correct copy of the 

above and foregoing document was served in accordance with the Federal Rules of Civil Procedure 

to the Defendant City of Fort Worth and all parties seeking service in the instant case via the 

Court’s ECF system. Notice of this motion has been given to Defendant City of Fort Worth as 

shown in the certificate of conference below; no service is required to the Gonzalez Defendants, 

as they have failed to appear (see Fed. Rule Civ. Pro. 5(a)(2)).

/s/Warren V. Norred

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 3 of 35 PageID 313
PR-DJ-111 Military Status Affidavit (Rev. 11-2015)

© TexasLawHelp.org Page 1 of 1

Case No: ____________________

(Print court information exactly as it appears on your Petition)

In the (check one): 

District County Justice Court of:

County, Texas

Military Status Affidavit

State of Texas, County of 

(Print the name of county where this Affidavit is notarized)

The person who signed this affidavit appeared, in person, before me, the undersigned 

notary, and stated under oath: 

1. “My name is: .

First Middle Last

2. “The Respondent’s name is: .

First Middle Last

3. “I am the Petitioner in this case. I am an adult and of sound mind. I have personal

knowledge of the facts stated in this affidavit. “The facts stated in this affidavit are true and 

correct.

(Check all boxes that apply)

“I know that the Respondent is not in the military because I asked the U.S. Department of 

Defense to check their Defense Manpower Data Center (DMDC) database. DMDC notified 

me that the Respondent is not on active duty in any of the armed forces.

“I attached a true copy of the DMDC verification. (If you check this box, you must attach a copy of the 

DMDC verification. You can print a copy of the DMDC verification from this web address: 

https://www.dmdc.osd.mil/appj/scra/scraHome.do.)

“I know that the Respondent is not now in the military because:

“I do not know if the Respondent is in the military now. 

! Do not sign until you are in front of a notary !

Signature of Person Signing Affidavit Date

Notary fills out below.

State of Texas, County of ______________________________

Sworn to and subscribed before me, the undersigned notary, on (date) at a.m./p.m.

by_________________________________________________

 (Print name of person who is signing this Affidavit, NOT the notary’s name.) Notary’s Signature 

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 4 of 35 PageID 314
SSN:

Birth Date:

Last Name:

First Name:

Middle Name:

Status As Of:

Certificate ID:

Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of

the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and

Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.

HOWEVER, WITHOUT A SOCIAL SECURITY NUMBER, THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY

ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO. NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY

IDENTIFY AN INDIVIDUAL.

Michael V. Sorrento, Director

Department of Defense - Manpower Data Center

400 Gigling Rd.

Seaside, CA 93955

Department of Defense Manpower Data Center Results as of : 

SCRA

On Active Duty On Active Duty Status Date

Active Duty Start Date Active Duty End Date Status Service Component

This response reflects the individuals' active duty status based on the Active Duty Status Date

Left Active Duty Within 367 Days of Active Duty Status Date

Active Duty Start Date Active Duty End Date Status Service Component

This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date

The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date

Order Notification Start Date Order Notification End Date Status Service Component

This response reflects whether the individual or his/her unit has received early notification to report for active duty

Dec-XX-1982

GONZALEZ

EULISES 

ERUBIEL 

Oct-03-2022

4L6S3TLTKF5YQMM

Oct-03-2022 03:19:59 PM

5.15

NA NA No NA

NA NA No NA

NA NA No NA

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 5 of 35 PageID 315
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility

Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.

The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 3901 et seq, as amended) (SCRA) (formerly known as

the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the

individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family

member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the

protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service. Service contact

information can be found on the SCRA website's FAQ page (Q35) via this URL: https://scra.dmdc.osd.mil/scra/#/faqs. If you have evidence the person

was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked

against you. See 50 USC App. § 3921(c).

This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active

Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active

duty on the Active Duty Status Date.

More information on "Active Duty Status"

Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less

than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service

authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the

President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the

unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve

Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.

Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).

Coverage Under the SCRA is Broader in Some Cases

Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be

reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.

Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).

Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website

certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.

Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not

actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA

extend beyond the last dates of active duty.

Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA

are protected

WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing

erroneous information will cause an erroneous certificate to be provided.

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 6 of 35 PageID 316
PR-DJ-111 Military Status Affidavit (Rev. 11-2015)

© TexasLawHelp.org Page 1 of 1

Case No: ____________________

(Print court information exactly as it appears on your Petition)

In the (check one): 

District County Justice Court of:

County, Texas

Military Status Affidavit

State of Texas, County of 

(Print the name of county where this Affidavit is notarized)

The person who signed this affidavit appeared, in person, before me, the undersigned 

notary, and stated under oath: 

1. “My name is: .

First Middle Last

2. “The Respondent’s name is: .

First Middle Last

3. “I am the Petitioner in this case. I am an adult and of sound mind. I have personal

knowledge of the facts stated in this affidavit. “The facts stated in this affidavit are true and 

correct.

(Check all boxes that apply)

“I know that the Respondent is not in the military because I asked the U.S. Department of 

Defense to check their Defense Manpower Data Center (DMDC) database. DMDC notified 

me that the Respondent is not on active duty in any of the armed forces.

“I attached a true copy of the DMDC verification. (If you check this box, you must attach a copy of the 

DMDC verification. You can print a copy of the DMDC verification from this web address: 

https://www.dmdc.osd.mil/appj/scra/scraHome.do.)

“I know that the Respondent is not now in the military because:

“I do not know if the Respondent is in the military now. 

! Do not sign until you are in front of a notary !

Signature of Person Signing Affidavit Date

Notary fills out below.

State of Texas, County of ______________________________

Sworn to and subscribed before me, the undersigned notary, on (date) at a.m./p.m.

by_________________________________________________

 (Print name of person who is signing this Affidavit, NOT the notary’s name.) Notary’s Signature 

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 7 of 35 PageID 317
SSN:

Birth Date:

Last Name:

First Name:

Middle Name:

Status As Of:

Certificate ID:

Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of

the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and

Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.

HOWEVER, WITHOUT A SOCIAL SECURITY NUMBER, THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY

ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO. NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY

IDENTIFY AN INDIVIDUAL.

Michael V. Sorrento, Director

Department of Defense - Manpower Data Center

400 Gigling Rd.

Seaside, CA 93955

Department of Defense Manpower Data Center Results as of : 

SCRA

On Active Duty On Active Duty Status Date

Active Duty Start Date Active Duty End Date Status Service Component

This response reflects the individuals' active duty status based on the Active Duty Status Date

Left Active Duty Within 367 Days of Active Duty Status Date

Active Duty Start Date Active Duty End Date Status Service Component

This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date

The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date

Order Notification Start Date Order Notification End Date Status Service Component

This response reflects whether the individual or his/her unit has received early notification to report for active duty

Aug-XX-1974

GONZALEZ

GILBERTO 

GABRIEL 

Oct-03-2022

JK0TC0KT560BJQ2

Oct-03-2022 03:21:03 PM

5.15

NA NA No NA

NA NA No NA

NA NA No NA

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 8 of 35 PageID 318
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility

Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.

The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 3901 et seq, as amended) (SCRA) (formerly known as

the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the

individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family

member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the

protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service. Service contact

information can be found on the SCRA website's FAQ page (Q35) via this URL: https://scra.dmdc.osd.mil/scra/#/faqs. If you have evidence the person

was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked

against you. See 50 USC App. § 3921(c).

This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active

Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active

duty on the Active Duty Status Date.

More information on "Active Duty Status"

Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less

than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service

authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the

President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the

unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve

Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.

Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).

Coverage Under the SCRA is Broader in Some Cases

Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be

reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.

Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).

Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website

certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.

Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not

actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA

extend beyond the last dates of active duty.

Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA

are protected

WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing

erroneous information will cause an erroneous certificate to be provided.

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 9 of 35 PageID 319
Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 10 of 35 PageID 320
Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 11 of 35 PageID 321
Declaration of Warren V. Norred

“My name is Warren V. Norred, my date of birth is February 21, 1963, and my office address is 

515 E. Border Street, Arlington, TX 76010, U.S. I declare under penalty of perjury that the 

foregoing statement is true and correct.

1. I am an attorney and owner of Norred Law, PLLC and licensed to practice law in Texas.

2. I have been practicing law in the DFW area for over a decade and I am familiar with 

reasonable pricing for legal services in the State of Texas. 

3. I have previously testified regarding reasonable attorneys’ fees in Texas, in multiple courts,

and I have litigated in every federal court in Texas and every attached bankruptcy court. 

4. I have also litigated in federal courts in California and Kansas, and in the Fifth and Ninth and 

Federal Courts of Appeal. 

5. I have tried to verdict more than a dozen trials, the longest of which lasted ten (10) days, 

including jury deliberations. My most complex single federal case was a two-day patent case.

6. Beyond jury trials, I have completed several dozen cases to judgment involving fees. 

7. I was retained by Tony Jones to represent him in a suit against the City of Fort Worth, 

Eulises Gonzalez, and Gilberto Gonzalez. 

8. As part of my representation, I have filed Plaintiff’s Original Petition and all other 

documents in this case filed for Plaintiff. 

9. As of the date of this signing, my team and I have spent approximately 7.4 hours on this case

in support of the Defamation Per Se claim, for a total billable amount of $1,919.50, which 

includes filing fees and expenses. I have attached Exhibit 4A in support of these fees, which 

includes only segregated and apportioned fees for the defamation per se claim only.

Executed in Tarrant County, State of Texas on December 5, 2022.

/s/ 

Warren V. Norred

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 12 of 35 PageID 322
Total Billable Flat Fees

$0.00

Total Billable Hours

71.20 hours

Total Billable Amount

$16,535.75

Total Billable Expenses

$1,530.65

Time & Expenses for Tony Jones v. City of Fort Worth - 01/01/2021 - 10/17/2022

User

Billable Flat Fees

$0.00

Billable Hours

2.10 hours

Total Billable Amount

$252.00

Billable Expenses

$852.39

Non-Billable Expenses

$0.00

Non-Billable Hours

0.00 hours

Flat Fees

This user has no flat fees for the selected period.

Time Entries

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes

03/02/2022 Hourly Case Work $120.00/hr 1.20 $144.00 Yes Tony Jones v. City of Fort Worth Invoiced

 rec.d Arraignment setting, conflicts with State's counsel "takes no position" on continuing the date. Draft and file motion to

continue.

04/19/2022 Filing Document with Court $120.00/hr 0.30 $36.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Draft Efile envelope, filed petition, request citations

04/26/2022 Hourly Case Work $120.00/hr 0.20 $24.00 Yes Tony Jones v. City of Fort Worth Invoiced

 City filed for removal to federal court, rec'd and saved removal docs.

09/27/2022 Hourly Case Work $120.00/hr 0.40 $48.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Drafted and filed request for entry of default against Gonzalez defendants.

Expenses

Date Activity Cost Quantity Total Billable Case Link Status Inner-office Notes

04/19/2022 Filing Fee $384.81 1.0 $384.81 Yes Tony Jones v. City of Fort Worth Invoiced

 Filing and citation fees

04/28/2022 Service of Process $90.00 1.0 $90.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Service CFW, Falcon Invoice 36524

04/28/2022 Service of Process $135.00 1.0 $135.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Service Gonzalez Defendants, Falcon Invoice 63567

06/06/2022 Service Cost $242.58 1.0 $242.58 Yes Tony Jones v. City of Fort Worth Invoiced

 Service of Federal Summons on Gonzalez defendants

User

Billable Flat Fees

$0.00

Billable Hours

0.00 hours

Total Billable Amount

$0.00

Billable Expenses

$0.00

Non-Billable Expenses

$0.00

Non-Billable Hours

0.00 hours

Flat Fees

This user has no flat fees for the selected period.

Time Entries

This user has no time entries for the selected period.

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 13 of 35 PageID 323
Expenses

This user has no expenses for the selected period.

User

Billable Flat Fees

$0.00

Billable Hours

0.00 hours

Total Billable Amount

$0.00

Billable Expenses

$0.00

Non-Billable Expenses

$0.00

Non-Billable Hours

0.00 hours

Flat Fees

This user has no flat fees for the selected period.

Time Entries

This user has no time entries for the selected period.

Expenses

This user has no expenses for the selected period.

User

Billable Flat Fees

$0.00

Billable Hours

0.00 hours

Total Billable Amount

$0.00

Billable Expenses

$0.00

Non-Billable Expenses

$0.00

Non-Billable Hours

0.00 hours

Flat Fees

This user has no flat fees for the selected period.

Time Entries

This user has no time entries for the selected period.

Expenses

This user has no expenses for the selected period.

User

Billable Flat Fees

$0.00

Billable Hours

26.80 hours

Total Billable Amount

$6,130.00

Billable Expenses

$497.42

Non-Billable Expenses

$0.00

Non-Billable Hours

0.00 hours

Flat Fees

This user has no flat fees for the selected period.

Time Entries

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes

08/30/2021 Communication - Opposing counsel $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Case research and conferring with FW City Attorney regarding status of property.

08/31/2021 Communication - Opposing counsel $200.00/hr 2.00 $400.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Communication via phone and email with client, code compliance officer Wedell and Fort Worth City attorney Chris Austria in attempt to resolve

matter.

09/01/2021 Research $200.00/hr 1.50 $300.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Legal research of the Fort Worth city code to determine client's compliance therewith.

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 14 of 35 PageID 324
09/03/2021 Research $200.00/hr 0.40 $80.00 Yes Tony Jones v. City of Fort Worth Invoiced

Further legal research of FW property code, communication with client via phone.

09/17/2021 Research $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

Legal research + conference with warren and consultation with client.

09/30/2021 Draft Document $200.00/hr 0.50 $100.00 Yes Tony Jones v. City of Fort Worth Invoiced

Beginning draft of Petition + communication with client via phone.

10/12/2021 Draft Document $200.00/hr 2.00 $400.00 Yes Tony Jones v. City of Fort Worth Invoiced

Drafting petition, adding causes of action and researching relevant caselaw.

10/13/2021 Draft Document $200.00/hr 2.50 $500.00 Yes Tony Jones v. City of Fort Worth Invoiced

Drafting petition, continuing to add causes of action and conducting additional legal research.

10/14/2021 Draft Document $200.00/hr 0.50 $100.00 Yes Tony Jones v. City of Fort Worth Invoiced

Adding facts section to Original Petition.

11/09/2021 Draft Document $250.00/hr 2.00 $500.00 Yes Tony Jones v. City of Fort Worth Invoiced

Working on Petition, phone call w client, performing records request from municipal court and reviewing documents, 

11/10/2021 Meeting $250.00/hr 0.50 $125.00 Yes Tony Jones v. City of Fort Worth Invoiced

Meeting with client and reviewing relevant documents/photos in preparation for suit.

12/02/2021 Communication - Court $250.00/hr 0.50 $125.00 Yes Tony Jones v. City of Fort Worth Invoiced

Attempting to get citation for discarded items dismissed.

12/06/2021 Communication - Opposing counsel $250.00/hr 0.50 $125.00 Yes Tony Jones v. City of Fort Worth Invoiced

Conferring with Prosecutor re: dismissal or plea bargain; conferring with client via phone.

12/08/2021 Hearing, Attend. $250.00/hr 1.00 $250.00 Yes Tony Jones v. City of Fort Worth Invoiced

Hearing for general complaint citation.

12/09/2021 Hourly Case Work $250.00/hr 0.50 $125.00 Yes Tony Jones v. City of Fort Worth Invoiced

Working to get citation issue resolved.

12/13/2021 Phone Call $250.00/hr 0.20 $50.00 Yes Tony Jones v. City of Fort Worth Invoiced

Phone call and case review in attempt to resolve citation issue.

12/14/2021 Hourly Case Work $250.00/hr 0.50 $125.00 Yes Tony Jones v. City of Fort Worth Invoiced

Continuing to communicate with prosecutor and client regarding citation and related issues.

12/16/2021 Phone Call $250.00/hr 1.00 $250.00 Yes Tony Jones v. City of Fort Worth Invoiced

Calling code compliance officers to determine status of property, figuring out variance issues.

12/27/2021 Docket $250.00/hr 0.25 $62.50 Yes Tony Jones v. City of Fort Worth Invoiced

Docket preparation.

12/28/2021 Conference $250.00/hr 1.00 $250.00 Yes Tony Jones v. City of Fort Worth Invoiced

Meeting with client and conference w Warren re: open records request.

12/30/2021 Phone Call $250.00/hr 0.10 $25.00 Yes Tony Jones v. City of Fort Worth Invoiced

Call with client.

01/03/2022 Citation Payment $250.00/hr 0.25 $62.50 Yes Tony Jones v. City of Fort Worth Invoiced

Paid Citation, pleaded no contest.

01/03/2022 Research $250.00/hr 2.00 $500.00 Yes Tony Jones v. City of Fort Worth Invoiced

Variance application, property research, call with client.

01/04/2022 Record Request $250.00/hr 1.50 $375.00 Yes Tony Jones v. City of Fort Worth Invoiced

Compiling and submitting open records requests pertaining to code enforcement activity on 20 properties

01/05/2022 Phone Call $250.00/hr 0.10 $25.00 Yes Tony Jones v. City of Fort Worth Invoiced

Call to code compliance officer Wafer re: variance and inspection.

01/07/2022 Review Document $250.00/hr 0.50 $125.00 Yes Tony Jones v. City of Fort Worth Invoiced

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 15 of 35 PageID 325
 Reviewing public records sent by City of FW.

01/10/2022 Meeting $250.00/hr 1.00 $250.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Client meeting discussing nonconforming properties, reviewing and completing variance application, sending application out. Billing cut from 2.3 hours

to 1 hour due to decision not to go through with application process.

01/11/2022 Review Document $250.00/hr 0.50 $125.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Reviewing and Organizing Evidence for suit against FW et. al

01/14/2022 Case Analysis and Development $250.00/hr 1.00 $250.00 Yes Tony Jones v. City of Fort Worth Invoiced

01/19/2022 Draft Document $250.00/hr 0.50 $125.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Editing Original Petition to reference open records request.

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes

Expenses

Date Activity Cost Quantity Total Billable Case Link Status Inner-office Notes

01/03/2022 Citation Payment $497.42 1.0 $497.42 Yes Tony Jones v. City of Fort Worth Invoiced

 Payment of general complaint citation for City of Fort Worth #GA048269 - pleaded no contest as instructed by client. Payment in the amount of

$497.42 rendered to court.

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0.00 hours

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0.00 hours

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This user has no flat fees for the selected period.

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This user has no time entries for the selected period.

Expenses

This user has no expenses for the selected period.

User

Billable Flat Fees

$0.00

Billable Hours

0.00 hours

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$180.84

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0.00 hours

Flat Fees

This user has no flat fees for the selected period.

Time Entries

This user has no time entries for the selected period.

Expenses

Date Activity Cost Quantity Total Billable Case Link Status Inner-office Notes

01/12/2022 Fees $159.00 1.0 $159.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Site Plan from mysiteplan.com

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 16 of 35 PageID 326
03/18/2022 Postage $21.84 1.0 $21.84 Yes Tony Jones v. City of Fort Worth Invoiced

 Demand Letters via regular and CMRRR to: Eulises Gonzales 7021 0950 0002 2998 9931 and Heliodoro Reyes 7021 0950 0002 2998 9924

Date Activity Cost Quantity Total Billable Case Link Status Inner-office Notes

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This user has no expenses for the selected period.

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This user has no expenses for the selected period.

User

Billable Flat Fees

$0.00

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17.60 hours

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Flat Fees

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Time Entries

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes

08/25/2021 Phone Call $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Called to update client. re: status. We are attempting to negotiate with FW City attorney. If no response by end of week, we shall pursue demand

letter.

02/25/2022 Research $200.00/hr 2.00 $400.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Investigated antislapp challenge to pending petition. Petition will need to be amended to include a defamation claim

Scheduled to discuss recent finding with WN on 02/28

03/04/2022 Edit Document $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 17 of 35 PageID 327
Amended petition to included defamation claim and facts. MA to call client and clarify date discrepancies. Th to discuss defamation retraction issue re:

DL

03/09/2022 Demand Letter $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

New demand letter alleging defamation with malice (basis for code harassment suits in Texas), including demand for retraction.

03/09/2022 Draft Document $200.00/hr 0.30 $60.00 Yes Tony Jones v. City of Fort Worth Invoiced

Amended petition to include defamation damage law.

03/15/2022 Review Document $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

Reviewed arraignment setting notie from City of fort worth

04/19/2022 Conference $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

Spoke with MA and WN re: petition status. Its ready to file. MA to file.

04/21/2022 Review Document $200.00/hr 0.20 $40.00 Yes Tony Jones v. City of Fort Worth Invoiced

Reviewed Def's Answer. Based on affirmative defenses, it looks like they plan to file a ptj.

04/28/2022 Review Document $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

Reviewed Federal Court's Order Requiring Scheduling Conference and report for Contest of scheduling Order. MA to set up conference with counsel

for City, but no counsel has appeared for the defamers yet. Conference and prop scheudling order due on May 12

05/09/2022 Discovery $200.00/hr 0.20 $40.00 Yes Tony Jones v. City of Fort Worth Invoiced

Drafted initial disclosures. Passed to KF to add addresses and grammar check.

05/13/2022 Case Status Check $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

Need to draft joint status report

05/16/2022 Case Status Check $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

Joint status report from other side has been signed off on.

05/25/2022 Case Status Check $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

TH to draft discovery.

06/16/2022 Conference $200.00/hr 0.30 $60.00 Yes Tony Jones v. City of Fort Worth Invoiced

MA updated TH on citations. MA has reminded client 

TH to revised with WN on 6/20

06/20/2022 Case Status Check $200.00/hr 0.20 $40.00 Yes Tony Jones v. City of Fort Worth Invoiced

Updated WN on case status. Need discovery. TH to offload drafting to ER.

06/22/2022 Conference $200.00/hr 0.30 $60.00 Yes Tony Jones v. City of Fort Worth Invoiced

TH briefed ER re: discovery

07/13/2022 Hourly Case Work $200.00/hr 0.50 $100.00 Yes Tony Jones v. City of Fort Worth Invoiced

Reviewed citation status and conferred with WN about talking to OC and client about negotiated settlement with Fort Worth and focusing on neighbors.

07/14/2022 Discovery $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

Reviewed responsive docs from City in anticipation of meting with client tomorrow. Also review miscellaneous folder.

07/15/2022 Meeting $200.00/hr 0.90 $180.00 Yes Tony Jones v. City of Fort Worth Invoiced

Met with Client

07/18/2022 Phone Call $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

Discussed documents client is bringing over and family connections between private parties and code compliance.

07/18/2022 Phone Call $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

TH spoke with client. 

TH and WN conferred. WN to talk to OC 

07/29/2022 Research $200.00/hr 3.00 $600.00 Yes Tony Jones v. City of Fort Worth Invoiced

Researched and drafted an argument on probable cause per the client's request from the meeting.

08/11/2022 Case Status Check $200.00/hr 0.30 $60.00 Yes Tony Jones v. City of Fort Worth Invoiced

WN to talk to client and then to OC re: settelment. If no progress on those fronts need

discovery.

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 18 of 35 PageID 328
08/29/2022 Conference $200.00/hr 0.30 $60.00 Yes Tony Jones v. City of Fort Worth Invoiced

 TH to draft discovery on FW. GH to draft DJs against both individual defendants.

09/08/2022 Review Document $200.00/hr 0.40 $80.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Reviewed Motion to dismiss filed by OC.

09/12/2022 Conference $200.00/hr 0.20 $40.00 Yes Tony Jones v. City of Fort Worth Invoiced

 TH conferred with WN. SN to start 12b6 and pass to TH when SN leaves on vacation.

09/15/2022 Case Status Check $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

 The client says that his neighbor,

WN to call client.

09/16/2022 Draft Document $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Draft default judgment. Need to confer with WN.

09/21/2022 Case Status Check $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Confirmed SN still on 12b6 response.

09/26/2022 Case Status Check $200.00/hr 0.20 $40.00 Yes Tony Jones v. City of Fort Worth Invoiced

 KF drafting expert designations for WN to file. TH working on DJ and SN working on 12b6 response.

09/26/2022 Review Document $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Reviewed expert designation and passed to WN.

09/28/2022 Edit Document $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Sanity check 12b6 response

10/04/2022 Draft Document $200.00/hr 0.50 $100.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Drafted Motion for leave to amend.

10/05/2022 Case Status Check $200.00/hr 0.20 $40.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Need to file motion for leave to amend. Also need to settle on a mediator. MA on mediator.

10/10/2022 Case Status Check $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

 12b6 response and amended complaint have been filed. Waiting on FW's next move.

10/12/2022 Review Document $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Reviewed amended 12b6 response filed by FW. MA to calendar resposne date.

10/12/2022 Draft Document $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Began drafting response to City's amended 12b6. Drafted full response under class of one issue, but need to finish due process defense.

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes

Expenses

This user has no expenses for the selected period.

User

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0.00 hours

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0.00 hours

Flat Fees

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This user has no time entries for the selected period.

Expenses

This user has no expenses for the selected period.

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 19 of 35 PageID 329
User

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0.00 hours

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User

Billable Flat Fees

$0.00

Billable Hours

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Total Billable Amount

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Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 20 of 35 PageID 330
This user has no flat fees for the selected period.

Time Entries

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes

09/12/2022 Research $200.00/hr 3.00 $600.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Read pleadings and evidence, listened to recordings, scanned through emails

09/14/2022 Draft Document $200.00/hr 3.20 $640.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Began draft of response, described property, began shell defenses on claims, mostly 4th amendment search's claims and citation work to set up 14th

amendment claim bolstering

09/27/2022 Draft Document $200.00/hr 4.00 $800.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Talk to W regarding drafts, finish up 4th amendment case law search, review 12b6 again, begin drafting amended complaint and revising 12b6

response

09/28/2022 Draft Document $200.00/hr 4.00 $800.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Finish drafting 12b6 response and amended complaint

Expenses

This user has no expenses for the selected period.

User

Billable Flat Fees

$0.00

Billable Hours

7.00 hours

Total Billable Amount

$3,093.75

Billable Expenses

$0.00

Non-Billable Expenses

$0.00

Non-Billable Hours

0.00 hours

Flat Fees

This user has no flat fees for the selected period.

Time Entries

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes

04/19/2022 Draft Petition $425.00/hr 0.75 $318.75 Yes Tony Jones v. City of Fort Worth Invoiced

 Revise and last review of petitoin.

04/20/2022 Hearing, Attend. $425.00/hr 1.50 $637.50 Yes Tony Jones v. City of Fort Worth Invoiced

 Arraignment hearing

08/30/2022 Phone Call $450.00/hr 0.25 $112.50 Yes Tony Jones v. City of Fort Worth Invoiced

 Phone discussing injunction and inspection. 

08/30/2022 Email $450.00/hr 0.20 $90.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Email to OC; 

09/27/2022 Review Document $450.00/hr 0.30 $135.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Reviewed and filed designation of experts. Reviewed and approved App for Entry of Default. MEA to file.

09/28/2022 Draft Response $450.00/hr 2.75 $1,237.50 Yes Tony Jones v. City of Fort Worth Invoiced

 Review and revise response and complaint, file.

10/04/2022 Draft Motion $450.00/hr 1.25 $562.50 Yes Tony Jones v. City of Fort Worth Invoiced

 Reviewed and revised motion to amend, email with nonopposition by KL.

Expenses

This user has no expenses for the selected period.

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 21 of 35 PageID 331
User

Billable Flat Fees

$0.00

Billable Hours

0.00 hours

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Flat Fees

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Time Entries

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Expenses

This user has no expenses for the selected period.

User

Billable Flat Fees

$0.00

Billable Hours

3.50 hours

Total Billable Amount

$700.00

Billable Expenses

$0.00

Non-Billable Expenses

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Non-Billable Hours

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Flat Fees

This user has no flat fees for the selected period.

Time Entries

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes

06/22/2022 Hourly Case Work $200.00/hr 1.50 $300.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Discovery Requests drafted in light of information gleaned from the City's responsive documents re our Open Records Requests. Conferred with WVN

re requesting responsive documents sans redactions.

06/24/2022 Draft Document $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Discovery Requests for Admission drafted regarding Defendant Gilberto Gonzalez's interactions and communications with Defendant City of Fort

Worth leading up to and during circumstances giving rise to suit.

06/24/2022 Draft Document $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Discovery Requests for Admission drafted regarding Defendant Eulises Gonzalez's interactions and communications with Defendant City of Fort Worth

leading up to and during circumstances giving rise to suit.

Expenses

This user has no expenses for the selected period.

User

Billable Flat Fees

$0.00

Billable Hours

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Total Billable Amount

$0.00

Billable Expenses

$0.00

Non-Billable Expenses

$32.16

Non-Billable Hours

0.00 hours

Flat Fees

This user has no flat fees for the selected period.

Time Entries

This user has no time entries for the selected period.

Expenses

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 22 of 35 PageID 332
Date Activity Cost Quantity Total Billable Case Link Status Inner-office Notes

09/10/2021 Postage $32.16 1.0 $32.16 No Tony Jones v. City of Fort Worth Invoiced

Demand Letter sent to Christopher Austria Assistant City Attorney City Attorneyâ€TMs Office 200 Texas St. Fort Worth, TX 76102 Via Regular Mail and

Certified Mail Return Receipt Requested CMRRR No. 7020 1290 0000 2470 7368 Christopher.austria@fortworthtexas.gov Eulises Gonzales 4312 Ave

H. Fort Worth, TX 76105 Via Regular Mail and Certified Mail Return Receipt Requested CMRRR No. 7020 1290 0000 2470 7351 Heliodoro Reyes

4328 Ave H. Fort Worth, TX 76105 Via Regular Mail and Certified Mail Return Receipt Requested CMRRR No. 7020 1290 0000 2470 7375

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 23 of 35 PageID 333
Declaration of Warren V. Norred

“My name is Warren V. Norred, my date of birth is February 21, 1963, and my office address is 

515 E. Border Street, Arlington, TX 76010, U.S. I declare under penalty of perjury that the 

foregoing statement is true and correct.

1. I am an attorney and owner of Norred Law, PLLC and licensed to practice law in Texas.

2. I have been practicing law in the DFW area for over a decade and I am familiar with 

reasonable pricing for legal services in the State of Texas. 

3. I have previously testified regarding reasonable attorneys’ fees in Texas, in multiple courts,

and I have litigated in every federal court in Texas and every attached bankruptcy court. 

4. I have also litigated in federal courts in California and Kansas, and in the Fifth and Ninth and 

Federal Courts of Appeal. 

5. I have tried to verdict more than a dozen trials, the longest of which lasted ten (10) days, 

including jury deliberations. My most complex single federal case was a two-day patent case.

6. Beyond jury trials, I have completed several dozen cases to judgment involving fees. 

7. I was retained by Tony Jones to represent him in a suit against the City of Fort Worth, 

Eulises Gonzalez, and Gilberto Gonzalez. 

8. As part of my representation, I have filed Plaintiff’s Original Petition and all other 

documents in this case filed for Plaintiff. 

9. As of the date of this signing, my team and I have spent approximately 7.4 hours on this case

in support of the Defamation Per Se claim, for a total billable amount of $1,919.50, which 

includes filing fees and expenses. I have attached Exhibit 4A in support of these fees, which 

includes only segregated and apportioned fees for the defamation per se claim only.

Executed in Tarrant County, State of Texas on December 5, 2022.

/s/ 

Warren V. Norred

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 24 of 35 PageID 334
Total Billable Flat Fees

$0.00

Total Billable Hours

71.20 hours

Total Billable Amount

$16,535.75

Total Billable Expenses

$1,530.65

Time & Expenses for Tony Jones v. City of Fort Worth - 01/01/2021 - 10/17/2022

User

Billable Flat Fees

$0.00

Billable Hours

2.10 hours

Total Billable Amount

$252.00

Billable Expenses

$852.39

Non-Billable Expenses

$0.00

Non-Billable Hours

0.00 hours

Flat Fees

This user has no flat fees for the selected period.

Time Entries

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes

03/02/2022 Hourly Case Work $120.00/hr 1.20 $144.00 Yes Tony Jones v. City of Fort Worth Invoiced

 rec.d Arraignment setting, conflicts with State's counsel "takes no position" on continuing the date. Draft and file motion to

continue.

04/19/2022 Filing Document with Court $120.00/hr 0.30 $36.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Draft Efile envelope, filed petition, request citations

04/26/2022 Hourly Case Work $120.00/hr 0.20 $24.00 Yes Tony Jones v. City of Fort Worth Invoiced

 City filed for removal to federal court, rec'd and saved removal docs.

09/27/2022 Hourly Case Work $120.00/hr 0.40 $48.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Drafted and filed request for entry of default against Gonzalez defendants.

Expenses

Date Activity Cost Quantity Total Billable Case Link Status Inner-office Notes

04/19/2022 Filing Fee $384.81 1.0 $384.81 Yes Tony Jones v. City of Fort Worth Invoiced

 Filing and citation fees

04/28/2022 Service of Process $90.00 1.0 $90.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Service CFW, Falcon Invoice 36524

04/28/2022 Service of Process $135.00 1.0 $135.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Service Gonzalez Defendants, Falcon Invoice 63567

06/06/2022 Service Cost $242.58 1.0 $242.58 Yes Tony Jones v. City of Fort Worth Invoiced

 Service of Federal Summons on Gonzalez defendants

User

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0.00 hours

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$0.00

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0.00 hours

Flat Fees

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Time Entries

This user has no time entries for the selected period.

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 25 of 35 PageID 335
Expenses

This user has no expenses for the selected period.

User

Billable Flat Fees

$0.00

Billable Hours

0.00 hours

Total Billable Amount

$0.00

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$0.00

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$0.00

Non-Billable Hours

0.00 hours

Flat Fees

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Expenses

This user has no expenses for the selected period.

User

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$0.00

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0.00 hours

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Flat Fees

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Time Entries

This user has no time entries for the selected period.

Expenses

This user has no expenses for the selected period.

User

Billable Flat Fees

$0.00

Billable Hours

26.80 hours

Total Billable Amount

$6,130.00

Billable Expenses

$497.42

Non-Billable Expenses

$0.00

Non-Billable Hours

0.00 hours

Flat Fees

This user has no flat fees for the selected period.

Time Entries

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes

08/30/2021 Communication - Opposing counsel $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Case research and conferring with FW City Attorney regarding status of property.

08/31/2021 Communication - Opposing counsel $200.00/hr 2.00 $400.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Communication via phone and email with client, code compliance officer Wedell and Fort Worth City attorney Chris Austria in attempt to resolve

matter.

09/01/2021 Research $200.00/hr 1.50 $300.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Legal research of the Fort Worth city code to determine client's compliance therewith.

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 26 of 35 PageID 336
09/03/2021 Research $200.00/hr 0.40 $80.00 Yes Tony Jones v. City of Fort Worth Invoiced

Further legal research of FW property code, communication with client via phone.

09/17/2021 Research $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

Legal research + conference with warren and consultation with client.

09/30/2021 Draft Document $200.00/hr 0.50 $100.00 Yes Tony Jones v. City of Fort Worth Invoiced

Beginning draft of Petition + communication with client via phone.

10/12/2021 Draft Document $200.00/hr 2.00 $400.00 Yes Tony Jones v. City of Fort Worth Invoiced

Drafting petition, adding causes of action and researching relevant caselaw.

10/13/2021 Draft Document $200.00/hr 2.50 $500.00 Yes Tony Jones v. City of Fort Worth Invoiced

Drafting petition, continuing to add causes of action and conducting additional legal research.

10/14/2021 Draft Document $200.00/hr 0.50 $100.00 Yes Tony Jones v. City of Fort Worth Invoiced

Adding facts section to Original Petition.

11/09/2021 Draft Document $250.00/hr 2.00 $500.00 Yes Tony Jones v. City of Fort Worth Invoiced

Working on Petition, phone call w client, performing records request from municipal court and reviewing documents, 

11/10/2021 Meeting $250.00/hr 0.50 $125.00 Yes Tony Jones v. City of Fort Worth Invoiced

Meeting with client and reviewing relevant documents/photos in preparation for suit.

12/02/2021 Communication - Court $250.00/hr 0.50 $125.00 Yes Tony Jones v. City of Fort Worth Invoiced

Attempting to get citation for discarded items dismissed.

12/06/2021 Communication - Opposing counsel $250.00/hr 0.50 $125.00 Yes Tony Jones v. City of Fort Worth Invoiced

Conferring with Prosecutor re: dismissal or plea bargain; conferring with client via phone.

12/08/2021 Hearing, Attend. $250.00/hr 1.00 $250.00 Yes Tony Jones v. City of Fort Worth Invoiced

Hearing for general complaint citation.

12/09/2021 Hourly Case Work $250.00/hr 0.50 $125.00 Yes Tony Jones v. City of Fort Worth Invoiced

Working to get citation issue resolved.

12/13/2021 Phone Call $250.00/hr 0.20 $50.00 Yes Tony Jones v. City of Fort Worth Invoiced

Phone call and case review in attempt to resolve citation issue.

12/14/2021 Hourly Case Work $250.00/hr 0.50 $125.00 Yes Tony Jones v. City of Fort Worth Invoiced

Continuing to communicate with prosecutor and client regarding citation and related issues.

12/16/2021 Phone Call $250.00/hr 1.00 $250.00 Yes Tony Jones v. City of Fort Worth Invoiced

Calling code compliance officers to determine status of property, figuring out variance issues.

12/27/2021 Docket $250.00/hr 0.25 $62.50 Yes Tony Jones v. City of Fort Worth Invoiced

Docket preparation.

12/28/2021 Conference $250.00/hr 1.00 $250.00 Yes Tony Jones v. City of Fort Worth Invoiced

Meeting with client and conference w Warren re: open records request.

12/30/2021 Phone Call $250.00/hr 0.10 $25.00 Yes Tony Jones v. City of Fort Worth Invoiced

Call with client.

01/03/2022 Citation Payment $250.00/hr 0.25 $62.50 Yes Tony Jones v. City of Fort Worth Invoiced

Paid Citation, pleaded no contest.

01/03/2022 Research $250.00/hr 2.00 $500.00 Yes Tony Jones v. City of Fort Worth Invoiced

Variance application, property research, call with client.

01/04/2022 Record Request $250.00/hr 1.50 $375.00 Yes Tony Jones v. City of Fort Worth Invoiced

Compiling and submitting open records requests pertaining to code enforcement activity on 20 properties

01/05/2022 Phone Call $250.00/hr 0.10 $25.00 Yes Tony Jones v. City of Fort Worth Invoiced

Call to code compliance officer Wafer re: variance and inspection.

01/07/2022 Review Document $250.00/hr 0.50 $125.00 Yes Tony Jones v. City of Fort Worth Invoiced

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 27 of 35 PageID 337
 Reviewing public records sent by City of FW.

01/10/2022 Meeting $250.00/hr 1.00 $250.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Client meeting discussing nonconforming properties, reviewing and completing variance application, sending application out. Billing cut from 2.3 hours

to 1 hour due to decision not to go through with application process.

01/11/2022 Review Document $250.00/hr 0.50 $125.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Reviewing and Organizing Evidence for suit against FW et. al

01/14/2022 Case Analysis and Development $250.00/hr 1.00 $250.00 Yes Tony Jones v. City of Fort Worth Invoiced

01/19/2022 Draft Document $250.00/hr 0.50 $125.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Editing Original Petition to reference open records request.

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes

Expenses

Date Activity Cost Quantity Total Billable Case Link Status Inner-office Notes

01/03/2022 Citation Payment $497.42 1.0 $497.42 Yes Tony Jones v. City of Fort Worth Invoiced

 Payment of general complaint citation for City of Fort Worth #GA048269 - pleaded no contest as instructed by client. Payment in the amount of

$497.42 rendered to court.

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Date Activity Cost Quantity Total Billable Case Link Status Inner-office Notes

01/12/2022 Fees $159.00 1.0 $159.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Site Plan from mysiteplan.com

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 28 of 35 PageID 338
03/18/2022 Postage $21.84 1.0 $21.84 Yes Tony Jones v. City of Fort Worth Invoiced

 Demand Letters via regular and CMRRR to: Eulises Gonzales 7021 0950 0002 2998 9931 and Heliodoro Reyes 7021 0950 0002 2998 9924

Date Activity Cost Quantity Total Billable Case Link Status Inner-office Notes

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Time Entries

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes

08/25/2021 Phone Call $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Called to update client. re: status. We are attempting to negotiate with FW City attorney. If no response by end of week, we shall pursue demand

letter.

02/25/2022 Research $200.00/hr 2.00 $400.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Investigated antislapp challenge to pending petition. Petition will need to be amended to include a defamation claim

Scheduled to discuss recent finding with WN on 02/28

03/04/2022 Edit Document $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 29 of 35 PageID 339
Amended petition to included defamation claim and facts. MA to call client and clarify date discrepancies. Th to discuss defamation retraction issue re:

DL

03/09/2022 Demand Letter $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

New demand letter alleging defamation with malice (basis for code harassment suits in Texas), including demand for retraction.

03/09/2022 Draft Document $200.00/hr 0.30 $60.00 Yes Tony Jones v. City of Fort Worth Invoiced

Amended petition to include defamation damage law.

03/15/2022 Review Document $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

Reviewed arraignment setting notie from City of fort worth

04/19/2022 Conference $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

Spoke with MA and WN re: petition status. Its ready to file. MA to file.

04/21/2022 Review Document $200.00/hr 0.20 $40.00 Yes Tony Jones v. City of Fort Worth Invoiced

Reviewed Def's Answer. Based on affirmative defenses, it looks like they plan to file a ptj.

04/28/2022 Review Document $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

Reviewed Federal Court's Order Requiring Scheduling Conference and report for Contest of scheduling Order. MA to set up conference with counsel

for City, but no counsel has appeared for the defamers yet. Conference and prop scheudling order due on May 12

05/09/2022 Discovery $200.00/hr 0.20 $40.00 Yes Tony Jones v. City of Fort Worth Invoiced

Drafted initial disclosures. Passed to KF to add addresses and grammar check.

05/13/2022 Case Status Check $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

Need to draft joint status report

05/16/2022 Case Status Check $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

Joint status report from other side has been signed off on.

05/25/2022 Case Status Check $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

TH to draft discovery.

06/16/2022 Conference $200.00/hr 0.30 $60.00 Yes Tony Jones v. City of Fort Worth Invoiced

MA updated TH on citations. MA has reminded client 

TH to revised with WN on 6/20

06/20/2022 Case Status Check $200.00/hr 0.20 $40.00 Yes Tony Jones v. City of Fort Worth Invoiced

Updated WN on case status. Need discovery. TH to offload drafting to ER.

06/22/2022 Conference $200.00/hr 0.30 $60.00 Yes Tony Jones v. City of Fort Worth Invoiced

TH briefed ER re: discovery

07/13/2022 Hourly Case Work $200.00/hr 0.50 $100.00 Yes Tony Jones v. City of Fort Worth Invoiced

Reviewed citation status and conferred with WN about talking to OC and client about negotiated settlement with Fort Worth and focusing on neighbors.

07/14/2022 Discovery $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

Reviewed responsive docs from City in anticipation of meting with client tomorrow. Also review miscellaneous folder.

07/15/2022 Meeting $200.00/hr 0.90 $180.00 Yes Tony Jones v. City of Fort Worth Invoiced

Met with Client

07/18/2022 Phone Call $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

Discussed documents client is bringing over and family connections between private parties and code compliance.

07/18/2022 Phone Call $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

TH spoke with client. 

TH and WN conferred. WN to talk to OC 

07/29/2022 Research $200.00/hr 3.00 $600.00 Yes Tony Jones v. City of Fort Worth Invoiced

Researched and drafted an argument on probable cause per the client's request from the meeting.

08/11/2022 Case Status Check $200.00/hr 0.30 $60.00 Yes Tony Jones v. City of Fort Worth Invoiced

WN to talk to client and then to OC re: settelment. If no progress on those fronts need

discovery.

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 30 of 35 PageID 340
08/29/2022 Conference $200.00/hr 0.30 $60.00 Yes Tony Jones v. City of Fort Worth Invoiced

 TH to draft discovery on FW. GH to draft DJs against both individual defendants.

09/08/2022 Review Document $200.00/hr 0.40 $80.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Reviewed Motion to dismiss filed by OC.

09/12/2022 Conference $200.00/hr 0.20 $40.00 Yes Tony Jones v. City of Fort Worth Invoiced

 TH conferred with WN. SN to start 12b6 and pass to TH when SN leaves on vacation.

09/15/2022 Case Status Check $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

 The client says that his neighbor,

WN to call client.

09/16/2022 Draft Document $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Draft default judgment. Need to confer with WN.

09/21/2022 Case Status Check $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Confirmed SN still on 12b6 response.

09/26/2022 Case Status Check $200.00/hr 0.20 $40.00 Yes Tony Jones v. City of Fort Worth Invoiced

 KF drafting expert designations for WN to file. TH working on DJ and SN working on 12b6 response.

09/26/2022 Review Document $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Reviewed expert designation and passed to WN.

09/28/2022 Edit Document $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Sanity check 12b6 response

10/04/2022 Draft Document $200.00/hr 0.50 $100.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Drafted Motion for leave to amend.

10/05/2022 Case Status Check $200.00/hr 0.20 $40.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Need to file motion for leave to amend. Also need to settle on a mediator. MA on mediator.

10/10/2022 Case Status Check $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

 12b6 response and amended complaint have been filed. Waiting on FW's next move.

10/12/2022 Review Document $200.00/hr 0.10 $20.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Reviewed amended 12b6 response filed by FW. MA to calendar resposne date.

10/12/2022 Draft Document $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Began drafting response to City's amended 12b6. Drafted full response under class of one issue, but need to finish due process defense.

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes

Expenses

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Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 31 of 35 PageID 341
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Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 32 of 35 PageID 342
This user has no flat fees for the selected period.

Time Entries

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes

09/12/2022 Research $200.00/hr 3.00 $600.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Read pleadings and evidence, listened to recordings, scanned through emails

09/14/2022 Draft Document $200.00/hr 3.20 $640.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Began draft of response, described property, began shell defenses on claims, mostly 4th amendment search's claims and citation work to set up 14th

amendment claim bolstering

09/27/2022 Draft Document $200.00/hr 4.00 $800.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Talk to W regarding drafts, finish up 4th amendment case law search, review 12b6 again, begin drafting amended complaint and revising 12b6

response

09/28/2022 Draft Document $200.00/hr 4.00 $800.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Finish drafting 12b6 response and amended complaint

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Billable Hours

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Time Entries

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes

04/19/2022 Draft Petition $425.00/hr 0.75 $318.75 Yes Tony Jones v. City of Fort Worth Invoiced

 Revise and last review of petitoin.

04/20/2022 Hearing, Attend. $425.00/hr 1.50 $637.50 Yes Tony Jones v. City of Fort Worth Invoiced

 Arraignment hearing

08/30/2022 Phone Call $450.00/hr 0.25 $112.50 Yes Tony Jones v. City of Fort Worth Invoiced

 Phone discussing injunction and inspection. 

08/30/2022 Email $450.00/hr 0.20 $90.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Email to OC; 

09/27/2022 Review Document $450.00/hr 0.30 $135.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Reviewed and filed designation of experts. Reviewed and approved App for Entry of Default. MEA to file.

09/28/2022 Draft Response $450.00/hr 2.75 $1,237.50 Yes Tony Jones v. City of Fort Worth Invoiced

 Review and revise response and complaint, file.

10/04/2022 Draft Motion $450.00/hr 1.25 $562.50 Yes Tony Jones v. City of Fort Worth Invoiced

 Reviewed and revised motion to amend, email with nonopposition by KL.

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Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 33 of 35 PageID 343
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Time Entries

Date Activity Rate Duration Total Billable Case Link Status Inner-office Notes

06/22/2022 Hourly Case Work $200.00/hr 1.50 $300.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Discovery Requests drafted in light of information gleaned from the City's responsive documents re our Open Records Requests. Conferred with WVN

re requesting responsive documents sans redactions.

06/24/2022 Draft Document $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Discovery Requests for Admission drafted regarding Defendant Gilberto Gonzalez's interactions and communications with Defendant City of Fort

Worth leading up to and during circumstances giving rise to suit.

06/24/2022 Draft Document $200.00/hr 1.00 $200.00 Yes Tony Jones v. City of Fort Worth Invoiced

 Discovery Requests for Admission drafted regarding Defendant Eulises Gonzalez's interactions and communications with Defendant City of Fort Worth

leading up to and during circumstances giving rise to suit.

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$32.16

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Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 34 of 35 PageID 344
Date Activity Cost Quantity Total Billable Case Link Status Inner-office Notes

09/10/2021 Postage $32.16 1.0 $32.16 No Tony Jones v. City of Fort Worth Invoiced

Demand Letter sent to Christopher Austria Assistant City Attorney City Attorneyâ€TMs Office 200 Texas St. Fort Worth, TX 76102 Via Regular Mail and

Certified Mail Return Receipt Requested CMRRR No. 7020 1290 0000 2470 7368 Christopher.austria@fortworthtexas.gov Eulises Gonzales 4312 Ave

H. Fort Worth, TX 76105 Via Regular Mail and Certified Mail Return Receipt Requested CMRRR No. 7020 1290 0000 2470 7351 Heliodoro Reyes

4328 Ave H. Fort Worth, TX 76105 Via Regular Mail and Certified Mail Return Receipt Requested CMRRR No. 7020 1290 0000 2470 7375

Case 4:22-cv-00359-O Document 33 Filed 01/12/23 Page 35 of 35 PageID 345