Suarez v. U.S. Bank, NA, As Trustee

Western District of Texas, txwd-5:2019-cv-00704

NOTICE of No Response by Plaintiff/Counter Defendant by U.S. Bank, NA, as Trustee re [20] MOTION for Summary Judgment

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION FELIX ROBERT SUAREZ, § § Plaintiff/Counter-Defendant, § § v. § § Civil Action No. 5:19-cv-704-FB-ESC U.S. BANK TRUST NATIONAL § ASSOCIATION, AS TRUSTEE OF CVI § LCF MORTGAGE LOAN TRUST I, § § Defendant/Counter-Plaintiff. § NOTICE OF NO RESPONSE BY PLAINTIFF/COUNTER-DEFENDANT TO DEFENDANT/COUNTER-PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT Defendant/Counter-Plaintiff U.S. Bank Trust National Association, as Trustee of CVI LCF Mortgage Loan Trust I ("U.S. Bank" or "Defendant"), pursuant to the Local Rules, files this Notice of No Response by Plaintiff/Counter-Defendant Felix Robert Suarez ("Plaintiff/Counter- Defendant" or "Suarez") to its Motion for Summary Judgment ("Motion") and respectfully states: 1. Defendant/Counter-Plaintiff filed its Motion for Summary Judgment on September 20, 2019. [ECF Document No. 20]. 2. Pursuant to Local Rule 7.1(e), Plaintiff/Counter-Defendant's response to Defendant/Counter-Plaintiff's Motion for Summary Judgment was due on October 4, 2019. Accordingly, Defendant/Counter-Plaintiffs respectfully request the Court grant its Motion for Summary Judgment, and for all other and further relief to which it may be entitled. WHEREFORE, PREMISES CONSIDERED, Defendant/Counter-Plaintiff prays that its Motion for Summary Judgment be granted in its entirety. Defendant/Counter-Plaintiff asks that it be awarded all other relief to which it may be entitled. NOTICE OF NO RESPONSE BY PLAINTIFF/COUNTER-DEFENDANTS TO DEFENDANT/COUNTER-PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT MWZM: 18-000111-505 PAGE 1 Respectfully submitted, By: /s/ Philip W. Danaher MARK D. CRONENWETT Texas Bar No. 00787303 mcronenwett@mwzmlaw.com PHILIP W. DANAHER Texas Bar No. 24078395 pdanaher@mwzmlaw.com MACKIE WOLF ZIENTZ & MANN, P. C. 14160 North Dallas Parkway, Suite 900 Dallas, TX 75254 Telephone: (214) 635-2650 Facsimile: (214) 635-2686 ATTORNEYS FOR DEFENDANT / COUNTER-PLAINTIFF CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument was served via ECF Notification on this 10th day of October, 2019, upon the following: Robert C. Newark, III office@newarkfirm.com 1341 W. Mockingbird lane, Suite 600W Dallas, TX 75247 Counsel for Plaintiff /s/ Philip W. Danaher PHILIP W. DANAHER NOTICE OF NO RESPONSE BY PLAINTIFF/COUNTER-DEFENDANTS TO DEFENDANT/COUNTER-PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT MWZM: 18-000111-505 PAGE 2