Debtors’ Motion to Jointly Administer Cases

Page 1

Joyce W. Lindauer

State Bar No. 21555700

Joyce W. Lindauer Attorney, PLLC

1412 Main Street, Suite 500

Dallas, Texas 75202

Telephone: (972) 503-4033

Facsimile: (972) 503-4034

ATTORNEYS FOR WHITESTONE UPTOWN 

TOWER, LLC AND

PROPOSED ATTORNEYS FOR ALL OTHER 

BELOW-CAPTIONED DEBTORS

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

IN RE: §

§

WHITESTONE UPTOWN TOWER, LLC, § CASE NO. 23-32832-mvl-11

a/k/a Pillarstone Capital REIT Operating §

Partnership, §

§

WHITESTONE INDUSTRIAL- § CASE NO. 24-30653-swe-11

OFFICE, LLC, §

§

WHITESTONE OFFICES, LLC, § CASE NO. 24-30654-mvl-11

§

WHITESTONE CP WOODLAND § CASE NO. 24-30655-mvl-11

PH 2, LLC, §

§

PILLARSTONE CAPITAL REIT § CASE NO. 24-30656-swe-11

OPERATING PARTNERSHIP, LP, §

§

Debtors. §

DEBTORS’ MOTION TO JOINTLY ADMINISTER CASES

NO HEARING WILL BE CONDUCTED HEREON UNLESS A WRITTEN 

RESPONSE IS FILED WITH THE CLERK OF THE UNITED STATES 

BANKRUPTCY COURT AT 1100 COMMERCE STREET, ROOM 1254, 

DALLAS, TEXAS 75242 BEFORE CLOSE OF BUSINESS ON MARCH 29, 

2024, WHICH IS AT LEAST 21 DAYS FROM THE DATE OF SERVICE 

HEREOF. 

ANY RESPONSE SHALL BE IN WRITING AND FILED WITH THE 

CLERK, AND A COPY SHALL BE SERVED UPON COUNSEL FOR THE 

MOVING PARTY PRIOR TO THE DATE AND TIME SET FORTH 

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Debtors’ Motion to Jointly Administer Cases

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HEREIN. IF A RESPONSE IS FILED A HEARING MAY BE HELD WITH 

NOTICE ONLY TO THE OBJECTING PARTY. 

IF NO HEARING ON SUCH NOTICE OR MOTION IS TIMELY 

REQUESTED, THE RELIEF REQUESTED SHALL BE DEEMED TO BE 

UNOPPOSED, AND THE COURT MAY ENTER AN ORDER GRANTING 

THE RELIEF SOUGHT OR THE NOTICED ACTION MAY BE TAKEN.

TO THE HONORABLE UNITED STATES BANKRUPTCY COURT:

COME NOW Whitestone Uptown Tower, LLC, Whitestone Industrial-Office, LLC, 

Whitestone Offices, LLC, White CP Woodland Ph 2, LLC, and Pillarstone Capital REIT Operating 

Partnership, LP, the Chapter 11 Debtors in the above-styled and referenced bankruptcy cases filed 

in the United States Bankruptcy Court for the Northern District of Texas, Dallas Division (the 

“Debtors”), and file this their Debtors’ Motion to Jointly Administer Cases, and in support thereof 

would show unto the Court as follows:: 

1. On December 1, 2023, Whitestone Uptown Tower, LLC filed a voluntary petition 

for relief under Chapter 11 of the Bankruptcy Code, Case No. 23-32832, which is pending before 

the Honorable Michelle V. Larson.

2. On March 4, 2024, Whitestone Industrial-Office, LLC filed a voluntary petition for 

relief under Chapter 11 of the Bankruptcy Code, Case No. 24-30653, which is pending before the 

Honorable Scott W. Everett.

3. On March 4, 2024, Whitestone Offices LLC filed a voluntary petition for relief 

under Chapter 11 of the Bankruptcy Code, Case No. 24-30654, which is pending before the 

Honorable Michelle V. Larson.

4. On March 4, 2024, White CP Woodland Ph 2, LLC filed a voluntary petition for 

relief under Chapter 11 of the Bankruptcy Code, Case No. 24-30655, which is pending before the 

Honorable Michelle V. Larson.

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Debtors’ Motion to Jointly Administer Cases

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5. On March 4, 2024, Pillarstone Capital REIT Operating Partnership, LP filed a 

voluntary petition for relief under Chapter 11 of the Bankruptcy Code, Case No. 24-30656, which 

is pending before the Honorable Scott W. Everett.

6. The Debtors are “affiliates” or “insiders” of one another within the meaning of 

sections 101(2) and 101(31) of the United States Bankruptcy Code. Joint administration of their 

estates is appropriate under Fed. R. Bankr P. 1015(b).

7. Consistent with this Court’s Local Bankruptcy Rule 1015-1(a), the Debtors are 

filing this Motion in each of the above-captioned cases. Also pursuant to LBR 1015-1(a), the 

Debtors seek determination of this Motion before the Honorable Michelle V. Larson, the Judge 

presiding over the case of Whitestone Uptown Tower, LLC, the first related case filed in this 

district.

8. The joint administration of the Debtors’ cases will allow the Court to use a single 

docket for each case and to combine notices to creditors and other parties-in-interest. The Debtors 

anticipate that the notices, applications, motions, other pleadings, hearings, and orders in these 

cases will affect each of the Debtors. With joint administration, the Debtors will save time and 

money and avoid duplicative and potentially confusing filings, by permitting parties to use a single 

caption on numerous documents and file most documents in one case, and to file a joint plan of 

reorganization. In addition, joint administration will ensure that the parties-in-interest in each 

Debtor’s case will be apprised of the various matters before the Court.

9. This is not a motion for substantive consolidation of the Debtors’ estates. The rights 

of parties in interest will not be prejudiced by entry of an order directing joint administration of 

the Debtors’ separate chapter 11 cases. Each creditor and party in interest will maintain its rights 

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Debtors’ Motion to Jointly Administer Cases

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in the particular estate against which it allegedly holds a claim or right. The rights of all creditors 

will be enhanced by the reduction in costs resulting from joint administration. 

10. The Debtors request that the official caption to be used by all parties in all pleadings 

in the jointly administered cases be as follows:

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

IN RE: §

§

WHITESTONE UPTOWN TOWER, LLC, § CASE NO. 23-32832-mvl-11

a/k/a Pillarstone Capital REIT Operating §

Partnership, §

§

WHITESTONE INDUSTRIAL- § CASE NO. 24-30653-swe-11

OFFICE, LLC, §

§

WHITESTONE OFFICES, LLC, § CASE NO. 24-30654-mvl-11

§

WHITESTONE CP WOODLAND § CASE NO. 24-30655-mvl-11

PH 2, LLC, §

§

PILLARSTONE CAPITAL REIT § CASE NO. 24-30656-swe-11

OPERATING PARTNERSHIP, LP, §

§ (Jointly Administered Under

Debtors. § Case No. 23-32832-mvl-11)

11. Counsel for Debtors will file with the Court a consolidated master mailing list 

(matrix) in the affected cases for future noticing requirements.

WHEREFORE, PREMISES CONSIDERED, the Debtors respectfully request the Court to 

enter an order in each of the Debtors’ cases: 

(i) directing the joint administration of the Debtors’ chapter 11 cases for procedural 

purposes only, 

(ii) approving the caption for jointly administrated cases substantially in the form 

provided herein, and

(iii) granting such other and further relief as is just and proper.

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Debtors’ Motion to Jointly Administer Cases

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Dated: March 8, 2024.

Respectfully submitted,

 /s/ Joyce W. Lindauer

Joyce W. Lindauer

State Bar No. 21555700

Joyce W. Lindauer Attorney, PLLC

1412 Main Street, Suite 500

Dallas, Texas 75202

Telephone: (972) 503-4033

Facsimile: (972) 503-4034

ATTORNEYS FOR DEBTOR

WHITESTONE UPTOWN TOWER, LLC 

and PROPOSED ATTORNEYS FOR ALL

OTHER ABOVE-CAPTIONED DEBTORS

CERTIFICATE OF SERVICE

The undersigned hereby certifies that on March 8, 2024, a true and correct copy of the 

foregoing document was served via United States first class mail, postage prepaid, upon the U.S. 

Trustee and the parties on the attached service list.

 /s/ Joyce W. Lindauer

Joyce W. Lindauer

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SERVICE LIST

Oice of the United States Trustee

1100 Commerce Street, Room 976

Dallas, TX 75242

RSS MSBAM2013-C13-TX WUT, LLC

c/o Stephen P. Drobny

Jones Walker LLP

201 S. Biscayne Blvd. Suite 3000

Miami, FL 33131

Whitestone REIT Operating 

 Partnership, LP

c/o Richards, Layton & Finger, P.A.

One Rodney Square

920 N. King Street

Wilmington, DE 19801

Costar

PO Box 7410099

Chicago, IL 60674-5099

AT&T

PO Box 6463

Carol Stream, IL 60197-6463

Comcast

PO Box 60533

City of Industry, CA 91716

Newlane Finance

PO Box 7358

Philadelphia, PA 19101-7358

Fed Ex

PO Box 660481

Dallas, TX 75266

Spectrum VOIP

PO Box 733619

Dallas, TX 75373-3619

Equifax Information Services

PO Box 71221

Charlotte, NE 28272

Montgomery County Tax Oice

400 N. San Jacinto St.

Conroe, TX 77301

Southern Montgomery County MUD

25212 Interstate 45

Spring, TX 77386

Albert Ramirez

9904 Hummingbird St.

La Porte, TX 77571

Ann Harris Bennett Tax Assessor

PO Box 4622

Houston, TX 77210

Spring Branch I.S.D.

Tax Assessor-Collector

PO Box 19037

Houston, TX 77224

West Park MUD Tax Assessor

PO Box 1819

Houston, TX 77251

A&G Electrical Service

24887 Lakeside Dr.

Hockley, TX 77448

Republic Services

PO Box 78829

Phoenix, AZ 85062

City of Houston – Water

PO Box 1560

Houston, TX 77251

West Park MUD

PO Box 2569

Spring, TX 77383

FirePro Tech, LLC

6830 N. Eldridge Pkwy, Suite 110

Houston, TX 77041

City of Houston

Solid Waste Management Dept.

PO Box 1562

Houston, TX 77251

John R. Ames, Tax Assessor

500 Elm St.

Dallas, TX 75202

Richardson ISD Tax Oice

970 Security Row

Richardson, TX 75081

TXU Energy

PO Box 650638

Dallas, TX 75265

Allied Universal Security Services

PO Box 101034

Pasadena, CA 91189

National Appraisal Partners, LLP

3203 Edloe Street

Houston, TX 77027

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Ambertun Construction

5920 Chisholm Trail

McKinney, TX 75070

Republic Services

PO Box 78829

Phoenix, AZ 85062

DHC Construction

11040 Timber Rd.

Cleveland, TX 77328

Mayte Molina

620 Esterine Rd.

Dallas, TX 75217

Southwest Engineers

PO Box 2499

Slidell, LA 70459

Waste Connections US, Inc.

PO Box 679859

Dallas, TX 75267

First Choice Coee Services

1500 Precision, Suite 130

Plano, TX 75074

The Dove Day Recycling Co.

PO Box 166602

Irving, TX 75016

Kings III of America, Inc.

751 Canyon Dr., Suite 100

Coppell, TX 75019

David Piwonka, Tax Assessor

10494 Jones Rd., Suite 106

Houston, TX 77065

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