NO. 03-15-00464-CV 

IN THE COURT OF APPEALS 

FOR THE 

THIRD SUPREME JUDICIAL DISTRICT 

AT AUSTIN, TEXAS 

 VICTORY CHEVAL HOLDINGS, LLC, GARRETT JENNINGS 

AND CASTLE CROWN MANAGEMENT, LLC, 

Appellants 

v. 

DENNIS ANTOLIK, VICTOR ANTOLIK 

and CHEVAL MANOR, INC., 

Appellees 

 APPELLANTS' FIRST AMENDED MOTION FOR CONTEMPT 

AND REFERRAL TO TRIAL COURT

TO THE HONORABLE COURT OF APPEALS: 

 Pursuant to T.R.A.P. 29.4, Appellants, Victory Cheval Holdings, LLC, Garrett 

Jennings, and Castle Crown Management, LLC move the Court to find Appellees, 

Victor Antolik, Dennis Antolik, and Cheval Manor, Inc., in contempt of the agreed 

portion of the Temporary Injunction now on interlocutory appeal before this Court as 

follows: 

ACCEPTED

03-15-00464-CV

7089903

THIRD COURT OF APPEALS

AUSTIN, TEXAS

9/24/2015 4:21:53 PM

JEFFREY D. KYLE

CLERK

 RECEIVED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 9/24/2015 4:21:53 PM JEFFREY D. KYLE Clerk
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1. Subsection B of the Temporary Injunction sets forth agreed injunctive 

relief that the parties agreed to in open Court and the Court ordered enforced. 

Subsection B6 provides as follows:

"Dennis Antolik, Victor Antolik, and Cheval Manor, Inc. shall keep all 

of the thirteen (13) horses that may be owned by them or business 

entities owned by them, or under their control, restrained behind a gated 

and secured fence...."

2. Appellants have failed to keep the horses restrained behind a gated and 

secured fence. Failure to keep the horses restrained behind a gated and secured fence 

was the cause of prior damage to the polo field and injury to persons on the property. 

It was probably the primary reason for the Court entering a temporary injunction.

3. This Court, by order dated September 10, 2015, has previously ordered 

Appellees' Motion for Contempt against Appellants referred to the trial court, The 

Honorable Karin Crump, for an evidentiary hearing pursuant to T.R.A.P. 29.4(a). 

Judge Crump has scheduled that hearing for 9:00 a.m. on September 30, 2015. 

Appellants respectfully request that the Court enter its order referring this Motion for 

Contempt for evidentiary hearing at the same time before Judge Crump.

WHEREFORE, Appellants respectfully pray that the Court enter its order 

referring this matter to Judge Crump for an evidentiary hearing pursuant to T.R.A.P. 

29.4(a), and for general relief.
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Respectfully submitted, 

/s/ Kemp Gorthey

Kemp W. Gorthey

State Bar No. 08221275

Kendall L. Bryant

State Bar No. 24058660

THE GORTHEY LAW FIRM

604 West 12th Street

Austin, Texas 78701

Tele: 512/236-8007

Fax: 512/479-6417

Email: kemp@gortheylaw.com

Email: kendall@gortheylaw.com

ATTORNEY FOR APPELLANTS, 

GARRETT JENNINGS and

CASTLE CROWN PROPERTIES

MANAGEMENT, LLC

and

/s/ Peyton Smith

PEYTON N. SMITH

Attorney in Charge

State Bar No. 18664350

Brian L. King

State Bar No. 24055776

REED & SCARDINO LLP

301 Congress Avenue, Suite 1250

Austin, Texas 78701

Tel: 512/474-2449

Fax: 512/474-2622

psmith@reedscardino.com

ATTORNEY FOR APPELLANT, 

VICTORY CHEVAL HOLDINGS, 

LLC
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CERTIFICATE OF CONFERENCE

On September 24, 2015, I received an email from counsel for Dennis 

Antolik stating the Appellees agree to Appellants’ request to refer Appellants’ 

Motion for Contempt to Judge Karin Crump of the 250th Civil District Court of 

Travis County, Texas for hearing at the same time as the Apellees’ motion set for 

September 30, 2015.

/s/ Kendall L. Bryant

Kendall L. Bryant

CERTIFICATE OF SERVICE

By my signature above, I hereby certify that a true and correct copy of the 

foregoing Appellants' Motion for Contempt and for Referral to Trial Court has been 

forwarded to Appellees' attorneys on this 24th day of September, 2015, as follows:

Mark Taylor Via Email: MarkT@hts-law.com

Taube Summers Harrison 

Taylor Meinzer Brown LLP

100 Congress Avenue, Suite 1800

Austin, Texas 78701

Donald R. Taylor Via Email: dtaylor@taylordunham.com

Isabelle M. Antongiorgi Via Email: ima@taylordunham.com

Taylor, Dunham & Rodriguez, LLP

301 Congress Avenue, Suite 1050

Austin, Texas 78701

Jack P. Bacon Via Email: hotbacon@me.com

3839 Bee Caves Road, Suite 100

Austin, Texas 78746