EXHIBIT B 

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Cause No. 296-00801-2017 

M.B., I.B. and J.S., § IN THE DISTRICT COURT 

 § 

Plaintiffs, § 

 § 

V. § 

 § 

MATTHEW GUY LANDGRAF, § 

KEVIN M. ROSS, TRUSTEE, FOR § 

THE USE AND BENEFIT OF § 296TH JUDICIAL DISTRICT 

MATTHEW GUY LANDGRAF, § 

KEVIN M. ROSS, Individually, § 

STi FAMILY HOLDINGS, LP, § 

STi FAMILY MANAGEMENT, LLC § 

and STi REAL ESTATE, LLC § 

 § 

Defendants. § COLLIN COUNTY, TEXAS 

INDEX OF DOCUMENTS FILED IN STATE COURT 

TAB DOCUMENT DATE

1. PLAINTIFFS’ ORIGINAL PETITION AND APPLICATION FOR TEMPORARY 

RESTRAINING ORDER, TEMPORARY INJUNCTION AND PERMANENT 

INJUNCTION 

02/16/17 

2. RETURN OF SERVICE – STI REAL ESTATE, LLC (POP) 03/06/17 

3. RETURN OF SERVICE – STI FAMILY MANAGEMENT, LLC (POP) 03/07/17 

4. AMENDED RETURN OF SERVICE – KEVIN ROSS (POP) 03/07/17 

5. AMENDED RETURN OF SERVICE – KEVIN ROSS (TRO) 03/07/17 

6. AMENDED RETURN OF SERVICE – KEVIN ROSS, TRUSTEE (POP) 03/07/17 

7. AMENDED RETURN OF SERVICE – KEVIN ROSS, TRUSTEE (TRO) 03/07/17 

8. AMENDED RETURN OF SERVICE – STI FAMILY HOLDINGS, LP (TRO) 03/07/17 

9. AMENDED RETURN OF SERVICE – STI REAL ESTATE, LLC (TRO) 03/07/17 

10. AMENDED RETURN OF SERVICE – STI FAMILY MANAGEMENT, LLC

(TRO) 

03/07/17 

11. RETURN OF SERVICE – KEVIN ROSS, INDIVIDUALLY (TRO) 03/10/17 

12. RETURN OF SERVICE – STI REAL ESTATE, LLC (TRO) 03/10/17 

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2 

13. RETURN OF SERVICE – STI FAMILY HOLDINGS, LP (TRO) 03/10/17 

14. RETURN OF SERVICE – STI FAMILY MANAGEMENT, LLC (TRO) 03/10/17 

15. RETURN OF SERVICE – KEVIN ROSS, TRUSTEE (TRO) 03/13/17 

16. ANSWER OF KEVIN ROSS, INDIVIDUALLY 03/17/17 

17. PLAINTIFF’S FIRST AMENDED PETITION 04/18/17 

18. AFFIDAVIT OF KEVIN ROSS 08/02/17 

19. ANSWER OF DEFENDANTS MATTHEW G. LANDGRAF AND KEVIN M.

ROSS, TRUSTEE FOR THE USE AND BENEFIT OF MATTHEW G.

LANDGRAF TO PLAINTIFFS’ FIRST AMENDED PETITION AND 

APPLICATION FOR TEMPORARY RESTRAINING ORDER

10/10/17 

20. NOTICE OF SET ASIDE OF FEDERAL JUDGMENT 11/16/17 

21. ORDER GRANTING TEMPORARY INJUNCTION IN PART AND DENYING 

TEMPORARY INJUNCTION IN PART

04/16/18 

22. CERTIFICATE OF ADDITIONAL CASH DEPOSIT IN LIEU OF SURETY BOND 04/24/18 

23. ORDER OF WITHDRAWAL OF COUNSEL (MATTHEW GILMARTIN) 01/22/19 

24. PLAINTIFFS’ MOTION TO ABATE PENDING ADJUDICATION OF 

UNDERLYING CLAIM

02/14/19 

25. ORDER GRANTING MOTION TO ABATE 02/14/19 

26. ORDER OF WITHDRAWAL OF COUNSEL (MICHAEL WESTON) 02/21/19 

27. SUGGESTION OF BANKRUPTCY 03/27/19 

28. ORDER OF DISMISSAL OF WANT OF PROSECUTION 12/15/22 

29. PLAINTIFFS’ MOTION TO REINSTATE 01/13/23 

30. ORDER GRANTING REINSTATEMENT 01/19/23 

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TAB 1 

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Cause No. _______________________

M.B., I.B. and J.S., § IN THE DISTRICT COURT

§

Plaintiffs, §

§

V. § 296TH JUDICIAL DISTRICT

§

MATTHEW GUY LANDGRAF, §

KEVIN M. ROSS, TRUSTEE, FOR §

THE USE AND BENEFIT OF §

MATTHEW GUY LANDGRAF, §

KEVIN M. ROSS, Individually, §

STi FAMILY HOLDINGS, LP, §

STi FAMILY MANAGEMENT, LLC §

and STi REAL ESTATE, LLC §

§

Defendants. § COLLIN COUNTY, TEXAS

PLAINTIFFS' ORIGINAL PETITION AND APPLICATION

FOR TEMPORARY RESTRAINING ORDER, TEMPORARY

INJUNCTION AND PERMANENT INJUNCTION

TO THE HONORABLE COURT:

M.B., I.B. and J.S. (“Plaintiffs)” complain of Matthew Guy Landgraf

(“Landgraf”), Kevin M. Ross, Trustee, for the use and benefit of Matthew Guy

Landgraf (“Landgraf Trust”), Kevin M. Ross, Individually ("Ross"), STi Family

Holdings, LP (“STi – LP”), STi Family Management, LLC (“STi – GP”) and STi

Real Estate, LLC (“STi Real Estate”), Defendants, and for causes of action would

show:

Filed: 2/16/2017 4:43:24 PM

Lynne Finley

District Clerk

Collin County, Texas

By LeAnne Brazeal Deputy

Envelope ID: 15371154

296-00801-2017

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I.

DISCOVERY CONTROL PLAN

1.1 Plaintiffs seek monetary relief over $1,000,000. Therefore, this suit is

subject to a Level 3 Discovery Control Plan.

II.

PARTIES AND SERVICE

2.1 Plaintiff, M.B. is an individual and a resident of the State of Florida.

2.2 Plaintiff, I.B. is an individual and a resident of the State of California.

2.3 Plaintiff, J.S. is an individual and a resident of the State of Texas.

2.4 Defendant, Matthew Guy Landgraf, an individual and a resident of the

State of Texas, may be served with process by delivering citation and a copy of

this petition to this Defendant at the Federal Bureau of Prisons, FCI Fort Worth,

3150 Horton Road, Fort Worth, Texas 76119.

2.5 Defendant, Kevin M. Ross, Trustee, for the use and benefit of

Matthew Guy Landgraf, an individual and a resident of the State of Texas, may be

served with process by delivering citation and a copy of this petition to this

Defendant at 1603 Lyndon B. Johnson Freeway, Suite 280 Dallas, Texas 75234.

2.6 Defendant, Kevin M. Ross, Individually, an individual and a resident

of the State of Texas, may be served with process by delivering citation and a copy

of this petition to this Defendant at 1603 Lyndon B. Johnson Freeway, Suite 280

Dallas, Texas 75234.

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2.7 Defendant STi Family Holdings, LP is a Texas limited partnership

and may be served with process by delivering citation and a copy of this petition to

Kevin M. Ross, its registered agent, at 1603 Lyndon B. Johnson Freeway, Suite

280 Dallas, Texas 75234.

2.8 Defendant STi Family Management, LLC is a Texas limited liability

company and may be served with process by delivering citation and a copy of this

petition to Kevin M. Ross, its registered agent, at 1603 Lyndon B. Johnson

Freeway, Suite 280 Dallas, Texas 75234.

2.9 Defendant STi Real Estate, LLC is a Texas limited liability company

and may be served with process by delivering citation and a copy of this petition to

Kevin M. Ross, its registered agent, at 1603 Lyndon B. Johnson Freeway, Suite

280 Dallas, Texas 75234.

III.

JURISDICTION AND VENUE

A. General Jurisdiction.

3.1 The subject matter in controversy is within the jurisdictional limits of

this court.

3.2 This court has jurisdiction over Defendant Matthew Guy Landgraf

because he is a Texas resident, and by virtue of a judgment entered against him in

Cause No. 296-02629-2016.

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3.3 This Court has jurisdiction over Defendant Kevin M. Ross, Trustee,

for the use and benefit of Matthew Guy Landgraf because he is a Texas resident.

3.4 This Court has jurisdiction over Defendant Kevin M. Ross,

Individually, because he is a Texas resident.

3.5 This court has jurisdiction over Defendant STi Family Holdings, LP

because it is a domestic limited partnership.

3.6 This court has jurisdiction over Defendant STi Family Management,

LLC because it is a domestic limited liability company.

3.7 This court has jurisdiction over Defendant STi Real Estate, LLC

because it is a domestic limited liability company.

B. Venue.

3.8 Venue in Collin County is proper in this cause under Sections 15.002

and 15.005 of the Texas Civil Practice and Remedies Code.

IV.

VIOLATION OF UNIFORM FRAUDULENT TRANSFER ACT

4.1 On March 22, 2012, Defendant Landgraf was arrested in connection

with charges of production of child pornography. Defendant Landgraf was

subsequently indicted April 12, 2012 on two counts of production of child

pornography involving Plaintiff M.B. A true and correct copy of the indictment is

attached hereto as Exhibit "A" and incorporated herein by reference. Although not

named in the criminal case, Plaintiffs I.B. and J.S. were also victims of Defendant

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Landgraf's criminal conduct. At the time of his arrest and indictment, Defendant

Landgraf was married to Plaintiffs M.B. and I.B.’s mother. Defendant Landgraf

pled guilty to the offenses charged and an Order finding Defendant Landgraf guilty

was entered November 13, 2012. A true and correct copy of the Order is attached

hereto as Exhibit "B" and incorporated herein by reference. A judgment of

conviction was entered and Defendant Landraf was finally sentenced on

November 21, 2013 to 180 months (15 years) in prison and was ordered to

surrender to the Federal Bureau of Prisons on January 21, 2014. A true and

correct copy of the Judgment in a Criminal Case is attached hereto as Exhibit "C"

and incorporated herein by reference. At the time of his arrest, Defendant

Landgraf knew or should have known the Plaintiffs’ civil claims against him had

accrued.

4.2 As of the date of his arrest, Defendant Landgraf owned the following

real property:

No. County Common Description Legal Description

1 Dallas 9210 Miles Road

Rowlett, Texas 750891

See Exhibit “D” attached

hereto and incorporated

herein.

1

Public records indicate that Defendant Landgraf’s step-father, W.N. Nichols, owns a Life Estate in this

property and Defendant Landgraf owned the Remainder at the time of his arrest.

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No. County Common Description Legal Description

2 Dallas 9214 Miles Road

Rowlett, Texas 75089

See Exhibit “E” attached

hereto and incorporated

herein.

4.3 On or about April 2, 2013, Defendant Landgraf created the Landgraf

Revocable Trust. Shortly thereafter, on July 22, 2013, Defendant Landgraf also

formed STi Family Holdings, LP, STi Family Management, LLC and STi Real

Estate, LLC (referred to collectively herein as the “Entity Defendants”).

Defendant Landgraf made certain capital contributions to the Entity Defendants.

Defendant Landgraf may have transferred other assets to the Entity Defendants.

Upon information and belief, Defendant Landgraf transferred his ownership

interests in the Entity Defendants, in whole or in part, to Defendant Landgraf Trust

on or about July 30, 2013. Thereafter on August 26, 2014, Defendant Landgraf

transferred his ownership interests in the property described in the preceding

paragraph by executing deeds conveying title to Defendant Landgraf Trust. See

Exhibits “F” and “G” attached hereto and incorporated herein.

4.4 Plaintiffs filed suit in Case No. 4:14-cv-00708 against Defendant

Landgraf in the United States District Court for the Eastern District of Texas on

November 7, 2014 alleging damages and injuries sustained as the result of

Defendant Landgraf’s criminal and tortious conduct that ultimately led to his

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incarceration. A Final Default Judgment was entered by the Court on April 6,

2016, a true and correct copy of which is attached hereto as Exhibit “H.”

Thereafter, the Judgment was registered in state court in the 296th District Court,

Collin County, Texas in Cause No. 296-02629-2016. This judgment became final

on July 26, 2016 and is a valid and subsisting judgment.

4.5 Defendant Landgraf transferred the property described above with the

intent to delay, hinder and defraud the Plaintiffs and others similarly situated.

Defendant Landgraf transferred the property with the intent of preventing the

Plaintiffs and others similarly situated from obtaining collection of their claims

described above. Additionally, Defendant Landgraf created the Landgraf Trust to

hide his assets and perpetrate a fraud or injustice on Plaintiffs. Furthermore, upon

information and belief, Defendant Landgraf formed the Entity Defendants for the

purpose of secreting his assets and perpetrating a fraud or injustice on Plaintiffs

and as part of an unfair device to achieve an inequitable result. Therefore, the

Court should disregard their legal fiction status to prevent their use as a cloak for

fraud or to work an injustice. Defendant Ross is a member of Defendant STi – GP,

which is the general partner of Defendant STi – LP and a member of Defendant

STi Real Estate.

4.6 The transfer of property to Defendant Landgraf Trust and/or to the

Entity Defendants violated the Uniform Fraudulent Transfer Act in that Defendant

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Landgraf transferred property to the Trust and/or the Entity Defendants with actual

intent to hinder, delay, or defraud Plaintiffs and other similarly situated.

Alternatively, Defendant Landgraf did not receive a reasonably equivalent value in

exchange for the transfers and he intended to incur, or believed or reasonably

should have believed that he would incur debts beyond his ability to pay as they

became due. Defendant Landgraf and/or Defendant Ross retained and retain

possession or control of the property transferred into the Trust and/or the Entity

Defendants. Moreover, the transfers were of substantially all of Defendant

Landgraf’s assets, which he attempted to conceal by the transfers, and occurred

shortly after a substantial debt was incurred.

4.7 Defendant Landgraf, who was incarcerated during most if not all of

the transfers, engaged in the foregoing transfer actions aided and abetted by

Defendant Ross and possibly others with full knowledge of Plaintiffs' claims.

Additionally, Defendant Ross actively participated in the attempted sale of real

property owned by Defendant Landgraf and/or Defendant Landgraf Trust. In so

doing, Defendant Ross conspired to defraud Plaintiffs by knowingly assisting

Defendant Landgraf in evading a judgment through fraudulent transfer.

4.8 Plaintiffs are entitled to avoidance of the transfers to the extent

necessary to satisfy Plaintiffs’ claims and/or attachment of the transferred property

and the proceeds from the sale of the transferred property. Alternatively, Plaintiffs

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are entitled to appointment of a receiver to take charge of the assets transferred

and/or the Entity Defendants, or any other relief the circumstances may require.

4.9 Plaintiffs are also entitled to personal judgment against Kevin M.

Ross, Trustee of Landgraf Revocable Trust, U/A/D April 2, 2013 for the value of

the property transferred to the Trust, as well as judgment against STi Family

Holdings, LP, STi Family Management, LLC and STi Real Estate, LLC for the

value of the property transferred to the Entity Defendants and/or Landgraf Trust.

Plaintiffs are further entitled to judgment for joint and several liability against

Defendant Ross for the value of all assets transferred aided and abetted by

Defendant Ross. Plaintiffs are further entitled to have execution issued and levied

on the transferred property.

4.10 In addition to other damages, under Business and Commerce Code

Section 24.013, Plaintiffs are entitled to costs and reasonable attorney’s fees as are

equitable and just.

V.

IMPOSITION OF CONSTRUCTIVE TRUST

5.1 The Plaintiffs incorporate by reference Sections I-IV above as if set

forth at length herein.

5.2 Plaintiffs request the Court impose a constructive trust on all property

of whatever kind or character held in the name of the Landgraf Trust or any of the

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Entity Defendants received by the Defendants as the result of a fraudulent transfer,

as well as the proceeds of sale thereof, for the benefit of Plaintiffs.

VI.

PUNITIVE/EXEMPLARY DAMAGES

6.1 The Plaintiffs incorporate by reference Sections I-V above as if set

forth at length herein.

6.2 Plaintiffs specifically allege that Defendants Landgraf, Landgraf

Trust, Ross, STi – LP, STi, STi – GP and STi Real Estate's wrongful conduct

complained of above relative to violations of Chapter 24 of the Texas Business and

Commerce Code were committed fraudulently and maliciously. Therefore,

Plaintiffs assert claims against Defendants for punitive/exemplary damages at the

highest amount allowed by law and without any cap or any other limitations due to

Defendants' knowing and/or intentional conduct described in §41.008(c)(10) of the

Texas Civil Practice and Remedies Code.

VII.

DECLARATORY JUDGMENT ACTION

7.1 A genuine controversy exists concerning the nature and

characterization of the real property owned by Defendants Landgraf and/or

Landgraf Trust and made the subject of this lawsuit. Specifically, the parties

disagree whether the real property the subject of this suit constitutes a Homestead,

and whether the real property is “urban” or “rural” for purposes of determining the

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nature and extent of any Homestead exemption, if any can be claimed on the

subject real property, which is denied.

7.2 Plaintiffs request the Court to declare that the real property the subject

of this action is not Defendant Landgraf’s homestead and is, therefore, non-exempt

real property of Defendant Landgraf and/or Defendant Landgraf Trust. In the

alternative, if the Court determines the subject real property is Defendant

Landgraf’s homestead, Plaintiffs request the Court to declare that the subject real

property is an urban homestead rather than a rural homestead.

VIII.

REQUEST FOR TEMPORARY RESTRAINING ORDER

AND TEMPORARY INJUNCTION

8.1 The Plaintiffs require injunctive relief to prevent the Defendants from

further alienating and transferring assets, and from encumbering existing assets of

Defendants, or assets subject to Defendants control, in violation of the Uniform

Fraudulent Transfer Act.

8.2 The Plaintiffs have alleged a cause of action against Defendants

arising from a valid and subsisting judgment and have shown a probable right of

recovery and likelihood of success on the merits. Failure to grant the requested

relief would allow Defendants to put assets beyond the reach of Plaintiffs and

render this litigation ineffectual. There is no adequate remedy at law and Plaintiffs

will suffer imminent, irreparable harm without Court intervention.

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8.3 As a direct and proximate result of the Defendants’ wrongful actions

as alleged in this petition, the Plaintiffs have suffered and will continue to suffer

imminent injury that will be irreparable and for which no adequate remedy at law

exists without the protections of a temporary restraining order and injunctive relief.

The Plaintiffs are willing to post the necessary reasonable bond to facilitate the

injunctive relief requested.

8.4 The only adequate, effective, and complete relief to the Plaintiffs is to

restrain the Defendants from further engaging in certain proscribed activities, as set

forth below. Pursuant to Tex. R. Civ. P. 680 et seq. and Tex. Bus. & Com. Code §

24.008(a)(3)(A), and in order to preserve the status quo during the pendency of this

action, the Plaintiffs seek a temporary restraining order, and on hearing, a

temporary injunction, ordering and immediately restraining the Defendants,

including the Defendants’ agents, servants, employees, independent contractors,

attorneys, representatives, and those persons or entities in active concert or

participation with them (collectively, the “Restrained Parties”) as follows:

a. Enjoining the Defendants from directly or indirectly, absolutely or

conditionally, voluntarily or involuntarily, disposing of or parting with

any assets of the Defendants or any interest in such assets.

b. Enjoining the Defendants from directly or indirectly, absolutely or

conditionally, voluntarily or involuntarily, disposing of or parting with

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any assets or any interest in such assets over which the Defendants

exercise control, directly or indirectly.

c. Enjoining the Defendants from leasing any assets of the Defendants or

any assets over which the Defendants exercise control, directly or

indirectly.

d. Enjoining the Defendants from creating a lien against or encumbering

any asset of the Defendants or any assets over which the Defendants

exercise control, directly or indirectly.

IX.

PRAYER

WHEREFORE, Plaintiffs request that Defendants be cited to appear and

answer herein and prays for the following relief:

a. A temporary restraining order, and upon hearing, a temporary

injunction for the relief requested above;

b. Judgment declaring that the transfers from Defendant Matthew Guy

Landgraf to Kevin M. Ross, Trustee of Landgraf Revocable Trust,

U/A/D April 2, 2013, STi Family Holdings, LP, STi Family

Management, LLC, and STi Real Estate, LLC, or between any of

them, are avoidable by Plaintiffs and for any other relief appropriate

under the circumstances;

c. Judgment against Defendants Matthew Guy Landgraf, Kevin M. Ross,

Trustee of Landgraf Revocable Trust, U/A/D April 2, 2013, Kevin M.

Ross, Individually, STi Family Holdings, LP, STi Family

Management, LLC, and STi Real Estate, LLC for attachment of the

transferred property and the proceeds from the sale of the transferred

property;

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d. Alternative judgment appointing a receiver to take charge of the assets

transferred and/or the Entity Defendants;

e. Judgment against Defendant Kevin M. Ross, Trustee of Landgraf

Revocable Trust, U/A/D April 2, 2013, for the value of the assets

transferred and the proceeds from the sale of the transferred assets;

f. Judgment against Defendant STi Family Holdings, LP for the value of

the assets transferred and the proceeds from the sale of the transferred

assets;

g. Judgment against Defendant STi Family Management, LLC for the

value of the assets transferred and the proceeds from the sale of the

transferred assets;

h. Judgment against Defendant STi Real Estate, LLC for the value of the

assets transferred and the proceeds from the sale of the transferred

assets;

i. Joint and several judgment against Defendant Kevin M. Ross,

Individually, for the value of all assets transferred aided and abetted

by Defendant Ross;

j. Imposition of a constructive trust as requested herein;

k. Judgment against Defendants Matthew Guy Landgraf, Kevin M. Ross,

Trustee, for the use and benefit of Matthew Guy Landgraf, Kevin M.

Ross, Individually, STi Family Holdings, LP, STi Family

Management, LLC and STi Real Estate, LLC for punitive/exemplary

damages at the highest amount allowed by law;

l. Judgment declaring that the subject real property is not Defendant

Landgraf’s homestead and is, therefore, non-exempt real property or,

alternatively, that the subject real property is an urban homestead and

not a rural homestead;

m. That execution be issued and levied on the transferred property;

n. Judgment awarding Plaintiffs post-judgment interest as provided by

law from the date of judgment until paid;

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o. Judgment awarding Plaintiffs costs of suit and reasonable attorney’s

fees as are equitable and just; and

p. Judgment awarding Plaintiffs such other and further relief to which

Plaintiffs may be justly entitled.

Respectfully submitted,

PECKAR & ABRAMSON, P.C.

By: /s/ Tracey L. Cloutier

Tracey L. Cloutier

State Bar No. 24031954

tcloutier@pecklaw.com

Timothy D. Matheny

State Bar No. 24000258

tmatheny@pecklaw.com

8080 N. Central Expressway

Suite 1600, LB 65

Dallas, Texas 75206-1819

(214) 523-5100 Telephone

(214) 521-4601 Facsimile

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MATTHEWS, SHIELS, KNOTT,

EDEN, DAVIS & BEANLAND, L.L.P.

By: /s/ Robert J. Davis

Daniel A. Knott

State Bar No. 11622700

dknott@mssattorneys.com

Robert J. Davis

State Bar No. 05543500

bdavis@mssattorneys.com

Crosspoint Atrium

8131 LBJ Freeway, Suite 700

Dallas, Texas 75251

(972) 234-3400 Telephone

(972) 234-1750 Facsimile

ATTORNEYS FOR PLAINTIFFS

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