# Opposition Brief — Hughes v. Houston Northwest Medical Center, Inc.

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## Record

- **Collection:** Supreme Court brief
- **Document type:** Opposition Brief
- **Published:** January 1, 1985
- **Citation:** 474 U.S. 1020

## Text

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Supreme Court, U.S,
ee ide ee ae

DOYS 1985

> \
; ¢
No. 85-640 =< JOSEPH F. SPANIOL, JR.
CLERK

————e

IN THE

Supreme Court of the United States

OCTOBER TERM, 1985

Louis B. HUGHES and
PHILIP T. EICHELBERGER, JR.,

Petitioners,

v.

HOUSTON NORTHWEST MEDICAL CENTER, INC., ET AL.,
Respondents.
ON WRIT OF CERTIORARI

To THE CourRT OF APPEALS FOR THE
First SUPREME JUDICIAL DISTRICT OF TEXAS

RESPONDENTS’ BRIEF IN OPPOSITION

NORMAN RIEDMUELLER
Krist, Kinney, Puckett &
Riedmueller
Five Post Oak Park — Suite 2260
Houston, Texas 77027-3416
(713) 963-8963

Counsel of Record
for all Respondents

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Of Counsel:

KEVIN MCEvILy
Butler & Binion
Allied Bank Plaza
Houston, Texas 77002
(713) 237-2020

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QUESTION PRESENTED

By their Petition for Writ of Certiorari (the “Petition’”’) peti-
tioners have presented this question:

Whether the finding below that petitioners’ appearance

before an administrative agency constituted tortious

interference with contract impermissibly infringed upon the
Petition clause of the First Amendment.

There was no such “finding below” by any court or jury. At
the trial of this case evidence was admitted concerning the con-
duct of Mrs. Reba Eichelberger, the wife of Petitioner Philip T.
Eichelberger, Jr., before an administrative agency. The evidence
was relevant on several grounds. No “finding” regarding
Mrs. Eichelberger was rendered at any level.

The petitioners before this Court never appeared before any
administrative agency. It was the wife of Petitioner Philip T.
Eichelberger, Jr.. who appeared before the administrative
agency.

In order to get to the substance of the issue petitioners seek to
raise, some restatement of the question presented will be
necessary.

(i)

LIST OF PARTIES

There are only three parties to the tortious interference judg-
ment being complained of:

(i) Houston North Hospital Properties, a Texas general
partnership, which recovered the judgment for tortious
interference;

(ii) Louis B. Hughes; and
(iii) Philip T. Eichelberger, Jr.

The individuals listed as respondents in the List of Parties in the
Petition are all interested in the matter because they are general
partners in Houston North Hospital Properties. They are not,
however, proper respondents before this Court.

Houston Northwest Medical Center, Inc. has no interest
whatever in the tortious interference judgment. Houston
Northwest Medical Center, Inc. prevailed on a counterclaim for
attorneys’ fees under article 5.14(F) of the Texas Business
Corporation Act based on a finding that petitioners had brought
their shareholders’ derivative suit without reasonable cause.’
That award is not the subject of the Petition. Houston
Northwest Medical Center, Inc. is not a proper respondent
before this Court.

‘See Appendix B to Petition, pp. 27a-28a.
(ii)

SUBJECT INDEX

PAGE
8 a i
I eS Gino baie sp baa d's oe sade cos ii
os Si epee vs ics eacvecesenes ili
ER PR oe ee cee iv
Yee es 8 te re l
REASONS FOR DENYING THE WRIT ............ 3
I. Petitioners kack Standing to Raise the Question
SIRES GES aR rn ae 3

Il. The Judgment Below Is Supported by an
Adequate and Independent State Ground of
Decision Because the Constitutional Question
Presented Now Was Not Raised Below ......... 4

Ill. Petitioners Have Demonstrated No
Unconstitutional Infringement of the Right to
Petition for Redress of Grievances ............. 7

SN 2 Cc kN hiss Sg aiia ohn’ sw VN oieiw ale 0 1]

(iii)

TABLE OF AUTHORITIES

PAGE
CASES
Austin Co. v. Vaughn Bldg. Corp., 643 S.W.2d 113

Sg EE ee ert he rads Be 6
Bill Johnson’s Restaurants, Inc. v. NLRB, 461 wv. es | ae

EON i oc Pen ese e's Kae eee es Rea 8
Broadrick v. Oklahoma, 413 U.S. 601 (1973) ......... 4
California Motor Transport Co. v. Trucking Unlimited,

ee es EE oe oc bee ah oe Saks 9
Eastern Railroad Presidents Conference v. Noerr Motor

Poatant, Tab., Deo A. 427 CIGGI) LW «5 onc cesses. 9
Engle v. Isaac, 456 U.S. 107 (1982) ................. 6
Feminist Women’s Health Center v. Mohammad, 586

i Bi. gi Tk Re . : RR eee ee ee 10
Gainesville vy. Florida Power & Light Co., 488 F.Supp.

SU UR ONG Gov cas 4 5 o6 Gk hee Sel ps ower ss
Hankerson v. North Carolina, 432 U.S. 233 (1977) .... 6
Herndon v. Georgia, 295 U.S. 441 (1935)............. 6
Household Goods Carriers’ Bureau v. Terrell, 452 F.2d

See RE 2s oo ie ak cc beaks eww 10
Hughes v. Aycock, 598 S.W.2d 370 (Tex.Civ.App. —

Houston [14th Dist.] 1980, writ refd n.r.e.) . |

Hughes v. Houston Northwest Medical Center, Dee. 647
S.W.2d 5 (Tex.App. — Houston [Ist Dist.}] 1980, no
| gee penn pin Rese ve a eT Bh renee fa Pe ee ee 2
Hughes v. Houston Northwest Medical Center, 680
S.W.2d 838 (Tex.App. — Houston [Ist Dist.] 1984,

ee re I eons sk Pe ks cae eae eae kn tees ss 7
INS v. Lopez-Mendoza, 104 S.Ct. 3479 (1984) ........ 6
McDonald v. Smith, 105 S.Ct. 2787 (1985) ........... 8

MCI Communications Corp. v. American Telephone &
Telegraph Co., 708 F.2d 1081 (7th Cir.), cert. denied,

PE Se ee IEE eS cu bead ha des eed s Caw o's 9
Michel v. Louisiana, 350 U.S. 91 (1955) ............. 6
Secretary of State of Maryland v. Joseph H. Munson

ig See es ANU hoes oa Koes 3

(iv)

United Mine Workers v. Pennington, 381 U.S. 657
| FORGES RE er nar eae ire Sieg TOS Dean hg Pe:

Wainwright v. Sykes, 433 U.S. 72 (1977) .............
Warth'¥. Seldiin, 422 US. GIO CUSTS) .. we cece

Watson v. Glens Falls Insurance Co., 505 S.W.2d 793
hl FR | epee etal giannylt ead ths De

Wolfe v. North Carolina, 364 U.S. 177 (1960) ........

STATUTES

Texas Business Corporation Act, art. 5.14(F)..........
TEX.REV.CIvV.STAT.ANN. art. 6643a..................

TEXAS RULES

Temes Rele of Eveemee Fe ois in hee ee eens
Texas Rule of Civil Procedure 274...................
Texas Rule of Civil Procedure 418 ...................
Texas Rule of Civil Procedure 469(e) ................

ARTICLES

Note, Standing to Assert Constitutional Jus Tertii, 88
ase, 0. Fes Ge CeO cco ce hen kos cee ueee

(v)

ve eee ee

No. 85-640

IN THE

Suureme Court of the United States

OCTOBER TERM, 1985

Louis B. HUGHES and
PHILip T. Ei1CHELBERGER, JR.,

Petitioners,
Vv.
HOUSTON NORTHWEST MEDICAL CENTER, INC., ET AL.,
Respondents.

On WRIT OF CERTIORARI
To THE CouRT OF APPEALS For THE
FIRST SUPREME JUDICIAL DISTRICT OF TEXAS

RESPONDENTS’ BRIEF IN OPPOSITION

STATEMENT OF THE CASE

In the early 1970's, petitioners Hughes and Eichelberger
joined a Texas general partnership, respondent Houston North
Hospital Properties. Because petitioners breached their duties as
partners, they were involuntarily retired from the partnership in
1975. A long and bitter court battle ended with the decision in
Hughes v. Aycock, 598 S.W.2d 370 (Tex.Civ.App. — Houston
[14th Dist.] 1980, writ refd n.r.e.), affirming a judgment oust-
ing petitioners as partners.

In mid-1982, the partnership announced that it had agreed to
sell the hospital it owned. Immediately after the agreement to
sell was announced but before a sale could be consummated,
petitioners launched an unrestrained assault to block the sale.
Specifically they did the following:

(1) they filed a baseless lawsuit;

2

(2) they filed groundless is pendens notices on the hospital
land and improvements; and

(3) they wrote threatening letters to the proposed purchaser
of the hospital.

In addition to these things, petitioners conspired with the wife of
one of them (Mrs. Reba Eichelberger) to have her appear osten-
sibly as an interested citizen before the Texas Health Facilities
Commission. The Commission was considering a request by the
prospective hospital purchaser for approval of a transfer of the
Certificate of Need to operate the hospital. None of these
respondents was a party to that administrative proceeding but
any delay there naturally delayed consummation of the hospit*!
sale.

It is, of course, easy to claim that your opponents’ lawsuit is
baseless but in this case it was proven six times over. The verdict
speaks for itself. See Appendix B to Petition, pp. 14a-29a. This
was a strike suit, plain and simple. As the state appellate court
held, the evidence at trial “would entitle, if not compel, the jury
to believe” that petitioners’ suit was all wrong, even without
regard to the four affirmative defenses which were also sustained
by the jury’s verdict. See Appendix A to Petition, p. 10a. As the
lower court indicated, if petitioners had simply made “[a]
reasonable inquiry” they would have seen that they had “no
reasonable cause to bring” this suit. /d. at 10a.

The facts regarding the lis pendens are equally disturbing. An
interlocutory appeal yielded the result that the respondents’
ability to free the hospital from petitioners’ lis pendens notices
under TeEx.REV.Civ.STAT.ANN. art. 6643a might depend
entirely upon how much money petitioners were claiming as
damages. See Hughes v. Houston Northwest Medical Center,
Inc., 647 S.W.2d 5 (Tex. App. — Houston [Ist Dist.] 1980, no
writ). Petitioners promptly increased their ad damnum to over
$62,000,000.

The merits of the petitioners’ suit were disproved at trial by
the testimony of their own witnesses. Any disinterested review of

3

the record would yield the conclusion that this case was brought
not in order to recover a judgment but in order to have a suit on
file for purposes akin to blackmail.

The tortious interference counterclaim of respondent Houston
North Hospital Properties was blessed with compelling merit.
The trial court correctly instructed the jury that they could base
a finding of tortious interference only upon action “done with the
purpose of causing [Houston .orth Hospital Properties]
damage or loss without justifiabl cause... .” Because every-
thing petitioners did was a sham, the jury returned a verdict for
Houston North Hospital Properties for tortious interference.

Yet here we are, three years later, still waiting to enforce our
judgment.

REASONS FOR DENYING THE WRIT

I.
PETITIONERS LACK STANDING TO RAISE
THE QUESTION PRESENTED HERE

Only Reba Eichelberger appeared before the administrative
agency in the purported exercise of a First Amendment right
under the Petition Clause. Only Drs. Hughes and Eichelberger
are petitioners before this Court. This is, then, a case of assertion
of jus tertii.

Someone once said that this Court’s general rule denying
standing to litigants asserting the rights of third parties “seems
honored only in the breach.” Note, Standing to Assert Constitu-
tional Jus Tertii, 88 Harv. L. Rev. 423, 425 (1974). It should be
honored in the observance here because it so distinctly applies
and because no exception to the rule is applicable.

As summarized by this Court most recently, the law of stand-
ing honored by this Court includes “prudential considerations
that limit the challenges courts are willing to hear.” Secretary of
State of Maryland v. Joseph H. Munson Co., 104 S.Ct. 2839
(1984). A litigant “generally must assert his own legal rights
and interests, and cannot rest his claim to relief on the legal

4

4
rights or interests of third parties.” Warth v. Seldin, 422 US.
490, 499 (1975).

The issue in this case becomes one of whether 2n exception
should be made in favor of petitioners.* Certainly none of the
exceptions previously created fits the facts of this case. Evén if
we focus on first Amendment cases, we see that there is nothing
preventing or “chilling” Mrs. Eichelberger’s freedom to asser:
her own rights. See Broadrick v. Oklahoma, 413 U.S. 601, 61z
(1973). The activity sought to be protected (objecting to an
administrative transfer of a certificate to operate a hospital) is
obviously not “at the heart” of Mrs. Eichelberger’s relationship
with the petitioners. See Munson, 104 S.Ct. at 2850.

Unless some new exception is to be created to fit the facts of
this case, the general rule against assertion of jus tertii deprives
petitioners of standing before this Court.

II.

THE JUDGMENT BELOW IS SUPPORTED BY AN
ADEQUATE AND INDEPENDENT STATE GROUND OF
DECISION BECAUSE THE CONSTITUTIONAL
QUESTION PRESENTED NOW WAS NOT RAISED
BELOW

Petitioners’ case has traveled from state District (trial) Court,
to the state Court of Appeals where judgment was affirmed, to
the Texas Supreme Court which considered the case in its deci-
sion to refuse petitioners’ writ, with a finding of “‘no reversible
error.” According to the Texas Rules of Evidence and the Texas
Rules of Civil Procedure, petitioners had at least three different
opportunities to assert that the conduct of Mrs. Reba
Eichelberger in appearing before an administrative agency was
protected by petitioners’ First Amendment rights. They were:

* Respondents note that the Petition in this case invokes no exception
to the general rule but merely declares: “Accordingly, the First
Amendment right to petition the government is variously refer-
enced to herein as belonging to both Mrs. Eichelberger and peti-
tioners.”” (Emphasis added) Petition, p. 4, n. 1.

5

1. The opportunity to object to the introduction of evidence
in the trial court on the ground of objection asserted
herein, viz, the infringement of petitioners’ First Amend-
ment rights;’

2. The opportunity to object to the charge to be presented to
the jury by specifying this complaint to that charge;*

3. The opportunity to present petitioners’ First Amendment
claims to the Court of Appeals under a “Point of Error”
in their Brief.°

At none of these stages in the proceedings below did petition-
ers assert any First Amendment right. And, although such a
complaint would probably have been considered waived by the
Texas Supreme Court’, petitioners never even mentioned the
First Amendment in their Application for Writ of Error to that
court.

* Texas Rule of Evidence 103(a)(1) provides that: “Error may not be
predicated upon a ruling which admits or excludes evidence unless
a substantial right of the party is affected, and objection or motion
to strike appears of record, stating the specific ground of objection,
if the specific ground was not apparent from the context.” During
the trial of this cause neither petitioners’ nor Mrs. Eichelberger’s
First Amendment rights were asserted. (Statement of Facts, pp.
960-973).

‘ Texas Rule of Civil Procedure 274 provides that “A party objecting
to a charge must point out distinctly the matter to which he objects
gud the grounds of his objection.” Petitioners’ objections to the
iwitious interference jury question had nothing to do with the
ground of objection they now assert. (Statement of Facts, pp. 1412-
1413).

* Texas Rule of Civil Procedure 418(d) requires that briefs contain
“fa] statement of the points upon which the appeal is predi-
cated .... Such points will be sufficient if they direct the attention
of the court to the error relied upon.”’ None of the Points of Error in
petitioners’ state Court of Appeals brief implicated any First
Amendment claims. See Brief for Appellants in the Court of
Appeals for the First Supreme Judicial District of Texas, pp. ix-xi
“Statement of Points of Error.”

® Texas Rule of Civil Procedure 469(e) requires that points raised in
an application for writ of error in the Texas Supreme Court “...
be assigned as error in the motion for rehearing in the Court of
Appeals... .”

6

Texas procedural law clearly provides many avenues for the
assertion and preservation of a claim of error. These petitioners
followed none of them.

If Texas is to have confidence in the finality of the decisigns of
its appellate courts, its rules of civil procedure cannot be lightly
disregarded. It is well established in Texas that a claim of error
is either preserved in the court below or lost. Austin Co. v.
Vaughn Bldg. Corp., 643 S.W.2d 113, 116 (Tex. 1982); Watson
v. Glens Falls Insurance Co., 505 S.W.2d 793, 797-98 (Tex.
1974). There can be no error in the judgment of the Court of
Appeals in Texas predicated on a point not preserved before that
Court. Watson v. Glens Falls Insurance Co., supra.

At trial and at both appellate levels, petitioners failed to take
advantage of the available mechanisms for the preservation of
error on their First Amendment claim. Petitioners’ waiver con-
stitutes an adequate and independent state ground of decision in
this case based on the legitimate interests of the State of Texas.

This Court has traditionally governed itself with the principles
of comity and orderly administration of justice by refusing to
review state court decisions based on nonfederal procedural
grounds that provide adequate and independent support for the
judgment, even in the presence of a substantial federal question.
See, e.g., Wolfe v. North Carolina, 364 U.S. 177 (1960); Michel
v. Louisiana, 350 U.S. 91 (1955); Herndon v. Georgia,'295 U.S.
441 (1935). Even in criminal cases where the life or liberty of
the petitioner may be at stake, a failure to preserve error accord-
ing to state rules results in waiver of the right to complain of
that error. Engle v. Isaac, 456 U.S. 107 (1982); Wainwright v.
Sykes, 433 U.S. 72 (1977); Hankerson v. North Carolina, 432
U.S. 233 (1977).

This Court has recently applied the rule that if the admission
of evidence is not objected to on a specific ground, that ground
cannot be used as the basis for an appeal. INS v. Lopez-
Mendoza, 104 S.Ct. 3479 (1984).

7

Petitioners nowhere explain their failure to properly raise a
First Amendment claim while they proceeded through the Texas
state court system. They have defaulted under each of the Texas
Rules of Civil Procedure cited above and have thereby waived
their right to cnallenge the judgment of the Texas courts.

iil.
PETITIONERS HAVE DEMONSTRATED NO
UNCONSTITUTIONAL INFRINGEMENT OF THE RIGHT
TO PETITION FOR REDRESS OF GRIEVANCES

A. The issue framed by the petitioners is not presented in this
litigation.
Petitioners attempt to bring a question before the Court which
is not presented by the litigation below. In fact, the Question
Presented in the Petition assumes an erroneous interpretation of

the judicial result and a subtly deceptive characterization of the
facts.

There was no “finding below that petitioners’ appearance
before an administrative agency constituted tortious interference
with contract.” Instead, the jury found, on the basis of all the
evidence admitted, “that Louis Hughes [and] Philip T.
Eichelberger, Jr. tortiously interfered with the contractual rela-
tions of Houston Norih Hospital Properties with respect to the
proposed purchaser of the hospital complex.”

There was evidence of an appearance before an administrative
agency, the Texas Health Facilities Commission, but it was the
appearance of neither of the petitioners. Reba Eichelberger’s
appearance before the agency was not the only evidence of peti-
tioners’ concerted effort to delay and prevent the sale of

* Special Issue No. 19 and the jury’s answer thereto is set out in
footnote 2 of the Opinion of the Court of Appeals of Texas for the
First Supreme Judicial District, Hughes v. Houston Northwest
Medical Center, Inc., 680 S.W.2d 838, 841 (Tex.App. — Houston
[ist Dist.] 1984, writ ref'd n.r.e.), reprinted as Appendix A to the
Petition (pp. 6a-7a). The issue also appears in the court’s charge,
reprinted as Appendix B to the Petition (pp. 26a-27a).

8

respondents’ valuable property. The legal and factual sufficiency
of the evidence was challenged in the state appellate courts
which, after close examination, concluded the evidence was suf-
ficient to support the judgment.’

f
B. The First Amendment issue petitioners raise has recently
been determined by this Court adversely to petitioners.

The evidence of Reba Eichelberger’s performance before the
Texas Health Facilities Commission supported, but was hardly
the sole basis for, respondents’ cause of action for tortious
interference. Petitioners’ argument that the affirmance of the
judgment “was wholly inconsistent with petitioners’ right to
freely inform the government of their wishes” is ultimately an
argument for absolute immunity. The limits of the First Amend-
ment right to petition the government were addressed by this
Court as recently as last term in McDonald v. Smith, 105 S.Ct.
2787 (1985). The unanimous Court was “not prepared to con- .
clude ... that the Framers of the First Amendment understood
the right to petition to include an unqualified right to express
damaging falsehoods in exercise of that right.” Jd. at 2790.
Similarly, there is nothing to suggest the Framers meant to insu-
late from liability those who would scheme to delay or prevent
other parties’ performance of a contract by needlessly invoking
the administrative procedures of a governmental agency.
Although petitioners would limit the implication of McDonald
to defamation cases (See Petition, p. 8, n. 2), this Court made
particuiar reference to the lack of absolute immunity in other
contexts:

Nor do the Court’s decisions interpreting the Petition
Clause in contexts other than defamation indicate that the
right to petition is absolute. For example, filing a complaint
in court is a form of petitioning activity; but “baseless liti-

gation is not immunized by the First Amendment right to
petition.” Bill Johnson’s Restaurants, Inc. v. NLRB, 461

* See Hughes v. Houston Northwest Medical Center, 680 S.W.2d
838, 842 (Tex.App. — Houston [Ist Dist.] 1984, writ refd n.r.e.),
reprinted on p. 8a of the Petition.

9

U.S. 731, 743 (1983); accord, California Motor Transport
Co. v. Trucking Unlimited, 404 U.S. 508 (1972).

The Petition offers no arguments for reconsideration of this
authority.

C. There is no conflict among the Courts of Appeals on any
issue in this case.

Without attempting to show how petitioners might benefit
from one of the allegedly conflicting descriptions of a sham, the
Petition urges the granting of the writ to resolve a conflict
among the Courts of Appeals by “defining the parameters of the
sham exception.” This case does not require any such resolution
of judicial conflict to resolve the issues in the case.

in MCI Communications Corp. v. American Telephone &
Telegraph Co., 708 F.2d 1081 (7th Cir.), cert. denied, 104 S.Ct.
234 (1983) a case cited by petitioners, the court noted that the
Noerr’ and Pennington’’ cases “themselves provide little defini-
tion of what a sham may be other than to indicate immunity for
‘genuine efforts’ or ‘good faith’ attempts to influence govern-
mental bodies.” 708 F.2d at 1155. The court found one of the
more cogent definitions of sham proceedings in Gainesville v.
Florida Power & Light Co., 488 F.Supp. 1258 (S.D. Fla. 1980):
Without a doubt, the intention to harm a competitor is

not sufficient to make litigation or administrative proceed-
ings a sham. That anticompetitive motive is the very matter
protected under Noerr-Pennington. Rather, the requisite
motive for the sham exception is the intent to harm one’s

competitors not by the result of the litigation but by the
simple fact of the institution of litigation.

Under this definition, or any other, the use of administrative
procedure solely as a ploy to hinder a party in the performance
of a contract is a sham.

* Eastern Railroad Presidents Conference v. Noerr Motor Freight,
Inc., 365 U.S. 127 (1961).

'° United Mine Workers v. Pennington, 381 U.S. 657 (1965); 488
F.Supp. at 1265-66 (emphasis in original); quoted at 708 F.2d at
1156.

10

D. The constitutional issue framed by petitioners does not
affect the judgment in the case.

As the judgment below was not predicated upon any finding
that Reba Eichelberger’s activities constituted a tortious
interference, the determination of the extent of her First
Amendment rights is immaterial to the outcome of the case. The
jury was charged to pass upon the conduct of the petitioners, not
Mrs. Eichelberger. In its answer to Special Issue 19, the jury
found petitioners’ interference with the contractual relations of
respondents without justifiable cause.

Even if Reba Eichelberger’s activity was absolutely immune,
the evidence of her activity was still admissible to show the pur-
pose and character of the actions of petitioners. United Mine
Workers v. Pennington, 381 U.S. at 670-71, n. 3; Feminist
Women’s Health Center v. Mohammad, 586 F.2d 539, 543, n. 7
(Sth Cir. 1978); Household Goods Carriers’ Bureau Vv. Terrell,
452 F.2d 152, 158, n. 18 (Sth Cir. 1971). Before the inter-
mediate Texas appeliate court, these petitioners argued against
the admissibility of this evidence on other grounds and lost. (See
Petition, Appendix A, p. 9a). No issue raised before this Court
would change the correctness of that ruling.

1]

CONCLUSION

There is no good reason to further delay justice in this case.
Respondents respectfully request that the Petition for Writ of
Certiorari in this case be denied in all respects.

Respectfully submitted,

NORMAN RIEDMUELLER
Krist, Kinney, Puckett &
Riedmueller
Five Post Oak Park —
Suite 2260
Houston, Texas 77027-3416
(713) 963-8963

Counsel of Record
for all Respondents

Of Counsel:

KEVIN MCEVILyY
Butler & Binion
Allied Bank Plaza
Houston, Texas 77002
(713) 237-2020

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385018_0890%3A2. Public record. Not legal advice.