PHH MORTGAGE’S STATUS REPORT PAGE 1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

JACK ROUBINEK, 

Plaintiff/Counter-Defendant, 

v. 

PHH MORTGAGE, 

Defendant/Counter-Plaintiff/ 

Third-Party Plaintiff, 

v. 

PATRICIA ROUBINEK, 

Third-Party Defendant. 

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CIVIL ACTION NO. 

3:22-cv-1889-K-BH 

PHH MORTGAGE’S STATUS REPORT 

Pursuant to the Court’s Order requiring a Status Report (the “Order”) (Doc. No. 43), 

Defendant/Counter-Plaintiff/Third-Party Plaintiff PHH Mortgage (“Defendant”) files this Report 

and states as follows: 

Defendant intends to pursue its counterclaims in furtherance of the right to foreclose in its 

own right and/or on behalf of the entity for which it services the underlying mortgage against 

Plaintiff/Counter-Defendant Jack Roubinek and Third-Party Defendant Patricia Roubinek, 

together with all other relief to which it is entitled. To accomplish this, Defendant intends to add 

any claim and party necessary to obtain the relief it seeks through pleading amendment, joinder, 

consolidation of actions, a substitution of parties, and/or any other appropriate procedural 

mechanism. Such action may involve, but not be limited to, adding an additional party, who is now 

making claims to the property in a separate lawsuit filed in state court. Upon ensuring the 

Case 3:22-cv-01889-K-BN Document 44 Filed 08/23/24 Page 1 of 3 PageID 236
PHH MORTGAGE’S STATUS REPORT PAGE 2 

appropriate claims and parties are added to the lawsuit, Defendant intends to conduct discovery, 

as needed, before moving for summary judgment on its counterclaims. Defendant expects its 

counterclaims will be resolved through summary judgment. However, Defendant intends to pursue 

its counterclaims through final judgment, including trial and any post-judgment proceedings, 

should it not obtain the relief it seeks through summary judgment. Defendant provides this 

explanation in response to the Court’s order as an overview of how it intends to proceed based on 

its current understanding of pertinent facts and circumstances. Defendant does so without waiving 

any rights, and while reserving the right to amend or supplement this explanation and to pursue 

the relief it seeks according to applicable law. 

Respectfully submitted, 

/s/ Camille Griffith

Robert T. Mowrey - Attorney-in-Charge

Texas Bar No. 14607500 

rmowrey@lockelord.com 

Matthew K. Hansen 

Texas Bar No. 24065368 

mkhansen@lockelord.com 

Camille Griffith 

Texas Bar No. 24034761 

camille.griffith@lockelord.com 

LOCKE LORD LLP 

2200 Ross Avenue, Suite 2800

Dallas, Texas 75201-2750 

(214) 740-8000 (Telephone) 

(214) 740-8800 (Facsimile) 

Helen O. Turner 

Texas Bar No. 24094229 

helen.turner@lockelord.com 

LOCKE LORD LLP

600 Travis Street, Suite 2800 

Houston, Texas 77002 

(713) 226-1280 (Telephone) 

(713) 229-2501 (Facsimile) 

Case 3:22-cv-01889-K-BN Document 44 Filed 08/23/24 Page 2 of 3 PageID 237
PHH MORTGAGE’S STATUS REPORT PAGE 3 

CERTIFICATE OF SERVICE 

The undersigned certifies that on August 23, 2024, a true and correct copy of the 

foregoing document was delivered to the following via ECF and/or CMRRR consistent with the 

Federal Rules of Civil Procedure: 

Thomas C. Barron 

Law Offices of Thomas C. Barron 

P.O. Box 14323 

Dallas, Texas 75214 

T: (214) 855-6631 

F: (214) 855-6633 

Email: tbarron@barronlawfirm.com

COUNSEL FOR PLAINTIFF/COUNTER-DEFENDANT JACK ROUBINEK

VIA CERTIFIED MAIL NO. 9214 7969 0099 9790 1653 3217 88 

RETURN RECEIPT REQUESTED

Patricia Roubinek, pro se

2126 Clearspring Dr. N. 

Irving, Texas 75063-5703 

THIRD-PARTY DEFENDANT 

/s/ Camille Griffith

Counsel for Defendant/Counter-Plaintiff/ThirdParty Plaintiff PHH Mortgage 

Case 3:22-cv-01889-K-BN Document 44 Filed 08/23/24 Page 3 of 3 PageID 238