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Todd Dotson’s lawsuit against Russ Whitney 1

John,

Seems like you have everything on Whitney but just in case you haven't seen
the information below it is the docket report and Trail Pleading for a case
in TX.

U.S. District Court
Northern District of Texas (Fort Worth)
CIVIL DOCKET FOR CASE #: 4:04-cv-00278

Dotson Consulting Group Inc et al v. Whitney Education Group Inc et al
Assigned to: Judge Terry R Means
Cause: 17:101 Copyright Infringement
Date Filed: 04/16/2004
Jury Demand: Both
Nature of Suit: 820 Copyright
Jurisdiction: Federal Question
Plaintiff
Dotson Consulting Group Inc represented by Mack Ed Swindle
Whitaker Chalk Swindle & Sawyer
City Center Tower II
301 Commerce St
Suite 3500
Fort Worth, TX 76102-4186
817/878-0500
Fax: 817/878-0501 FAX
Email: mswindle@whitakerchalk.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

David R Childress
Whitaker Chalk Swindle & Sawyer
City Center Tower II
301 Commerce St
Suite 3500
Fort Worth, TX 76102-4186
817/878-0506
Fax: 817/878-0501 FAX
Email: dchildress@whitakerchalk.com
ATTORNEY TO BE NOTICED

Plaintiff
Todd Dotson Training Systems Ltd represented by Mack Ed Swindle
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

David R Childress
(See above for address)
ATTORNEY TO BE NOTICED

Plaintiff
Todd Dotson
Individually represented by Mack Ed Swindle
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

David R Childress
(See above for address)
ATTORNEY TO BE NOTICED

V.

Defendant
Whitney Education Group Inc represented by William M Parrish
Jenkens & Gilchrist - Austin
401 Congress Ave
Suite 2500
Austin, TX 78701
512/499-3800
Fax: 512/404-3520 FAX
Email: bparrish@jenkens.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Andrew G DiNovo
Jenkens & Gilchrist - Austin
401 Congress Ave
Suite 2500
Austin, TX 78701
512/499-3800
Fax: 512/404-3520 FAX
Email: adinovo@jenkens.com
ATTORNEY TO BE NOTICED

Defendant
Whitney Leadership Group Inc represented by William M Parrish
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Andrew G DiNovo
(See above for address)
ATTORNEY TO BE NOTICED

Defendant
Russ Whitney represented by William M Parrish
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Andrew G DiNovo
(See above for address)
ATTORNEY TO BE NOTICED

Defendant
A C Johnson represented by Roger C Diseker
Kelly Hart & Hallman
201 Main St
Suite 2500
Fort Worth, TX 76102-3194
817/332-2500
Fax: 817/878-9280 FAX
Email: roger_diseker@khh.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Marshall M Searcy
Kelly Hart & Hallman
201 Main St
Suite 2500
Fort Worth, TX 76102-3194
817/332-2500
Fax: 817/878-9280 FAX
Email: marshall_searcy@khh.com
ATTORNEY TO BE NOTICED

Defendant
Jessanne Johnson represented by Roger C Diseker
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Marshall M Searcy
(See above for address)
ATTORNEY TO BE NOTICED

Defendant
Tim Veler represented by Roger C Diseker
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Marshall M Searcy
(See above for address)
ATTORNEY TO BE NOTICED

Defendant
Margaret Shorts represented by Roger C Diseker
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Marshall M Searcy
(See above for address)
ATTORNEY TO BE NOTICED

Defendant
Dana Van Hoose represented by Roger C Diseker
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Marshall M Searcy
(See above for address)
ATTORNEY TO BE NOTICED

Defendant
Todd Trygier represented by Roger C Diseker
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Marshall M Searcy
(See above for address)
ATTORNEY TO BE NOTICED

Defendant
James V Reed represented by Roger C Diseker
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Marshall M Searcy
(See above for address)
ATTORNEY TO BE NOTICED

Provider
John W Hughes represented by John W Hughes
Law Office of John W Hughes
6000 Western Place
Suite 100
Fort Worth, TX 76107
817/377-4800
Fax: 817/377-4821 FAX
Email: jwhughes@mediatortexas.com
PRO SE

Counter Claimant
Russ Whitney

Counter Claimant
Whitney Education Group Inc

Counter Claimant
Whitney Leadership Group Inc

V.

Counter Defendant
Dotson Consulting Group Inc

Counter Defendant
Todd Dotson Training Systems Ltd

Counter Defendant
Todd Dotson
Individually

Counter Claimant
A C Johnson

Counter Claimant
Jessanne Johnson

Counter Claimant
Tim Veler

Counter Claimant
Margaret Shorts

Counter Claimant
Dana Van Hoose

Counter Claimant
Todd Trygier

Counter Claimant
James V Reed

V.

Counter Defendant
Dotson Consulting Group Inc

Counter Defendant
Todd Dotson Training Systems Ltd

Counter Defendant
Todd Dotson
Individually

Date Filed # Docket Text
04/16/2004 1 COMPLAINT against Dana Van Hoose, A C Johnson, Jessanne
Johnson, James V Reed, Margaret Shorts, Todd Trygier, Tim Veler, Russ
Whitney, Whitney Education Group Inc, Whitney Leadership Group Inc ( Filing
fee $150; Receipt number 48659), filed by Todd Dotson, Dotson Consulting
Group Inc, Todd Dotson Training Systems Ltd.(dld, ) (Entered: 04/19/2004)
04/16/2004 2 CERTIFICATE OF INTERESTED PERSONS by Todd Dotson, Dotson
Consulting Group Inc, Todd Dotson Training Systems Ltd. (dld, ) (Entered:
04/19/2004)
04/16/2004 3 Summons Issued as to Dana Van Hoose, A C Johnson, Jessanne
Johnson, James V Reed, Margaret Shorts, Todd Trygier, Tim Veler, Russ
Whitney, Whitney Education Group Inc, Whitney Leadership Group Inc. (dld, )
(Entered: 04/19/2004)
05/19/2004 4 SUMMONS Returned Executed as to Whitney Leadership Group Inc
served by Secretary of State by certified mail, "return receipt dated
4/29/2004, bearing the Signature of Addressee's Agent", answer due
5/19/2004. (dld, ) (Entered: 05/20/2004)
05/19/2004 5 SUMMONS Returned Executed as to Whitney Education Group Inc
served by Secretary of State by certified mail, "return receipt dated
4/29/2004, bearing the Signature of Addressee's Agent", answer due
5/19/2004.(dld, ) (Entered: 05/20/2004)
05/19/2004 6 SUMMONS Returned Executed as to Dana Van Hoose served by
Secretary of State by certified mail, "return receipt dated 5/6/2004,
bearing the Signature of Addressee's Agent",answer due 5/26/2004. (dld, )
(Entered: 05/20/2004)
05/19/2004 7 SUMMONS Returned Executed as to Todd Trygier served by
Secretary of State by certified mail, "return receipt dated 4/29/2004,
bearing the Signature of Addressee's Agent", answer due 5/19/2004. (dld, )
(Entered: 05/20/2004)
05/19/2004 8 SUMMONS Returned Executed as to Margaret Shorts served by
Secretary of State by certified mail, "return receipt dated 4/29/2004,
bearing the Signature of Addressee", answer due 5/19/2004. (dld, ) (Entered:
05/20/2004)
05/20/2004 9 SUMMONS Returned Executed as to A C Johnson served by Secretary
of State by certified mail; return receipt dated 5/8/2004, bearing signature
of addressee; answer due 5/28/2004. (dld, ) (Entered: 05/24/2004)
05/20/2004 10 SUMMONS Returned Executed as to Jessanne Johnson served by
Secretary of State by certified mail; return receipt dared 5/8/2004, bearing
signature of address; answer due 5/28/2004. (dld, ) (Entered: 05/24/2004)
06/01/2004 11 Defendant's Original ANSWER to Complaint by Russ Whitney,
Whitney Education Group Inc, Whitney Leadership Group Inc.(wrb, ) (Entered:
06/03/2004)
06/01/2004 12 MOTION to Dismiss or, Alternatively, Motion for a More
Definite Statement and Supporting Brief by Dana Van Hoose, A C Johnson,
Jessanne Johnson, James V Reed, Margaret Shorts, Todd Trygier, Tim Veler
(wrb, ) (Entered: 06/03/2004)
06/03/2004 13 ORDER REQUIRING COMPLIANCE WITH LOCAL RULE..defts to file a
certificate of interested persons in compliance with Local Civil Rule 7.4
w/in 10 days of the entry of this order. (Signed by Judge Terry R Means on
06/03/04) (wrb, ) (Entered: 06/04/2004)
06/04/2004 14 CERTIFICATE OF INTERESTED PERSONS/DISCLOSURE STATEMENT by Dana
Van Hoose, A C Johnson, Jessanne Johnson, James V Reed, Margaret Shorts,
Todd Trygier, Tim Veler. (wrb, ) (Entered: 06/08/2004)
06/08/2004 15 Secretary of State RETURN OF SERVICE: summons/cmp mailed cmrr
by Secy of State to Russ Whitney, but returned 5/25/04 bearing notation
Unclaimed (pdm, ) (Entered: 06/09/2004)
06/14/2004 16 CERTIFICATE OF INTERESTED PERSONS/DISCLOSURE STATEMENT by Russ
Whitney, Whitney Education Group Inc, Whitney Leadership Group Inc. (wrb, )
(Entered: 06/15/2004)
06/18/2004 17 RESPONSE to Motion re 12 MOTION to Dismiss or Alternatively,
Motion for a More Definite Statement and brief in support of same filed by
Todd Dotson, Dotson Consulting Group Inc, Todd Dotson Training Systems Ltd.
(wrb, ) (Entered: 06/21/2004)
06/24/2004 18 ORDER TO SUBMIT JOINT STATUS REPORT AND PROPOSED DISCOVERY
PLAN...w/in 30 days of the date of the filing of this order. (Signed by
Judge Terry R Means on 6/24/04) (wrb, ) (Entered: 06/25/2004)
07/02/2004 19 Reply in Support of 12 MOTION to Dismiss or Alternatively
Motion for More Definite Statement filed by Dana Van Hoose, A C Johnson,
Jessanne Johnson, James V Reed, Margaret Shorts, Todd Trygier, Tim Veler.
(wrb, ) (Entered: 07/06/2004)
07/09/2004 20 UNFILED PER 20ORDER... MOTION for Leave to File Surreply to
Mentor Defendants' Reply in Support of Motion to Dismiss or, Alternatively,
Motion for a More Definite Statement by Todd Dotson, Dotson Consulting Group
Inc, Todd Dotson Training Systems Ltd (dld, ) Modified on 7/15/2004 (dld, ).
(Entered: 07/09/2004)
07/13/2004 21 ORDER denying 12 Motion to Dismiss and alternative motion for
a motion for a more definite statement (Signed by Judge Terry R Means on
7/13/04) (wrb, ) (Entered: 07/14/2004)
07/13/2004 22 Order Unfiling 20 MOTION for Leave to File Surreply to Mentor
Defendants' Reply in Support of Motion to Dismiss or, Alternatively, Motion
for a More Definite Statement filed by Dotson Consulting Group Inc, Todd
Dotson Training Systems Ltd, Todd Dotson due to the following deficiency:
Certificate of Conference is required. LR7.1(b).. (Signed by Judge Terry R
Means on 7/13/04) (dld, )...Cy of this order w/ orig & cy of M/LvF, proposed
order, & of surreply returned to Dave Childress (Entered: 07/15/2004)
07/23/2004 23 JOINT STATUS REPORT AND PROPOSED DISCOVERY PLAN by Todd
Dotson, Dotson Consulting Group Inc, Dana Van Hoose, A C Johnson, Jessanne
Johnson, James V Reed, Margaret Shorts, Todd Dotson Training Systems Ltd,
Todd Trygier, Tim Veler, Russ Whitney, Whitney Education Group Inc, Whitney
Leadership Group Inc. (wrb, ) (Entered: 07/26/2004)
07/28/2004 24 ANSWER to Complaint with Jury Demand by Dana Van Hoose, A C
Johnson, Jessanne Johnson, James V Reed, Margaret Shorts, Todd Trygier, Tim
Veler.(dld, ) (Entered: 07/29/2004)