Citizen Alerts

Estate Notices

CAUSE NO. 25-0739-CP4

ESTATE OF STEPHEN A. SUTTER

a/k/a STEPHEN ALLEN SUTTER a/k/a STEPHEN SUTTER, DECEASED

WILLIAMSON COUNTY, TEXAS

NOTICE TO CREDITORS

Notice is hereby given that original letters testamentary for the Estate of Stephen A. Sutter a/k/a Stephen Allen Sutter a/k/a Stephen Sutter, deceased, were issued on August 6, 2025, in Cause No. 25-0739-CP4 pending in County Court at Law No. 4, Williamson County, Texas, to:

LAWRENCE SALL

c/o Sandra M. Lefler / Brenda K. West

The Lefler Law Firm

1530 Sun City Blvd, Ste 119 Georgetown, Texas 78633

All persons having claims against this estate which is currently being administered are required to present them within the time and in the manner prescribed by law. All persons having claims should address them in care of the representative at the address stated above.

3605

Notice to Creditors

Notice is hereby given that original Letters Testamentary for the Estate of Billy Wayne Grizzard, Jr., Deceased, were issued on August 13, 2025, under Docket No. 25-0792-CP4, pending in the County Court at Law Number Four of Williamson County, Texas, to Alanah Rose Grizzard, of Georgetown, TX.

All persons having claims against this estate, which is currently being administered, are required to present them within the time and in the manner prescribed by law.

All claims should be addressed in care of the Independent Executor’s attorney, Elizabeth A. Sabol, at 201 S. Lakeline Boulevard, Suite 501, Cedar Park, Texas 78613.

Dated this 13th day of August, 2025.

Very truly yours,

Sabol Law PLLC

/s/ Elizabeth A. Sabol

by: Elizabeth A. Sabol

ATTORNEY FOR ALANAH ROSE GRIZZARD, INDEPENDENT

EXECUTOR OF THE ESTATE OF BILLY WAYNE GRIZZARD, JR., DECEASED

3606

CITATION BY PUBLICATION

THE STATE OF TEXAS COUNTY OF WILLIAMSON

TO ALL PERSONS INTERESTED IN THE ESTATE OF KENNETH WAYNE SIMS, DECEASED, Cause No. 25-0967-CP4, in County Court at Law #4 of Williamson County, 405 Martin Luther King Street, Georgetown, Texas 78626.

TRACY DIOHNNE HICKMAN, Applicant in the above numbered and entitled estate, filed on the 12th day of August, 2025 an APPLICATION FOR DETERMINAITON OF HEIRSHIP AND FOR ISSUANCE OF LETTERS OF INDEPENDENT ADMINISTRATION of the said estate and requests that the said Court determine who are the heirs and only heirs of the said KENNETH WAYNE SIMS, DECEASED, and their respective shares and interest in such estate.

Said application may be heard at 10:00 o’clock a.m. on or after the first Monday next after the expiration of ten days from the date of publication of this citation, at the Williamson County Justice Center in Georgetown, Williamson County, Texas.

All persons interested in said estate are hereby cited to appear before said Honorable Court on or before above-mentioned time and place by filing a written answer contesting such application should they desire to do so.

If this citation is not served within 90 days after the date of its issuance, it shall be returned unserved.

Issued and given under my hand and seal of office at Georgetown, Texas, this the 13th day of August, 2025.

Applicant’s Attorney:

Stephen Foster

8000 Centre Park Drive #200 Austin, TX 78754

Nancy E. Rister

Williamson County Clerk 405 MLK Street, Box 14 Georgetown, Texas 78626

By: /S/Brandi Dimler, Deputy

3608

NOTICE TO CREDITORS

Notice is hereby given that original Letters Testamentary for the Estate of Billy Arthur Morgan, Deceased, were issued on August 13, 2025, in Cause No. 25-0321-CP4, pending in the County Court of Williamson County, Texas, to: James Timothy Morgan.

All persons having claims against this Estate which is currently being administered are required to present them to the undersigned within the time and in the manner prescribed by law.

c/o: Carter & Denham, PLLC

808 N. Ave. C, P.O. Box 669 Elgin, Texas 78621

DATED the 13th of August, 2025.

CARTER & DENHAM, PLLC

s/s Christopher Denham

W. Christopher Denham

State Bar No.: 24052139

808 N. Avenue C Elgin, Texas 78621

Telephone: (512) 538-2292 Facsimile: (512) 285-6855

E-mail: cdenham@carterdenham.com

Attorney for James Timothy Morgan

3610

NOTICE TO CREDITORS

Notice is given that original Letters Testamentary for the Estate of Mary Louise Wade were issued on August 5, 2025, in Cause No. 25-0541-CP4, pending in the County Court at Law Number 4 of Williamson County, Texas, to Pamela Sue Major. All persons having claims against the estate, which is presently being administered, are required to submit them, within the time and manner prescribed by law, and before the estate is closed, addressed as follows:

c/o Pamela Sue Major

3110 Magnolia Blvd Temple, Texas 76502

Dated ______August 14, 2025_______________________

/s/ Buck Major

Buck Major

Attorney for Executor of the Estate of Mary Louise Wade

3614

NOTICE TO CREDITORS

Notice is given that original Letters Testamentary for the Estate of C. L. Wade were issued on August 5, 2025, in Cause No. 25-0788-CP4, pending in the County Court at Law Number 4 of Williamson County, Texas, to Pamela Sue Major. All persons having claims against the estate, which is presently being administered, are required to submit them, within the time and manner prescribed by law, and before the estate is closed, addressed as follows:

c/o Pamela Sue Major

3110 Magnolia Blvd Temple, Texas 76502

Dated ______August 14, 2025_______________________

/s/ Buck Major

Buck Major

Attorney for Executor of the Estate of C. L. Wade

3615

CITATION BY PUBLICATION

THE STATE OF TEXAS COUNTY OF WILLIAMSON

TO ALL PERSONS INTERESTED IN THE ESTATE OF TROY PERRY A/K/A TROY DANIEL PERRY A/K/A TROY D. PERRY, DECEASED, Cause No. 25-0966-CP4, in County Court at Law #4 of Williamson County, 405 Martin Luther King Street, Georgetown, Texas 78626.

OLIVIA PERRY, ALSO KNOWN AS OLIVIA MONTGOMERY PERRY, Applicant in the above numbered and entitled estate, filed on the 12th day of August, 2025 an APPLICATION TO DETERMINE HEIRSHIP AND FOR LETTERS OF INDEPENDENT ADMINISTRATION of the said estate and requests that the said Court determine who are the heirs and only heirs of the said TROY PERRY A/K/A TROY DANIEL PERRY A/K/A TROY D. PERRY, DECEASED, and their respective shares and interest in such estate.

All persons interested in said estate are hereby cited to appear before said Honorable Court on or before above mentioned time and place by filing a written answer contesting such application should they desire to do so.

If this citation is not served within 90 days after the date of its issuance, it shall be returned unserved.

Issued and given under my hand and seal of office at Georgetown, Texas, this the 12th day of August, 2025.Applicant’s Attorney:

Brenda K. West

1530 Sun City Blvd, Ste 119 Georgetown TX 78633

Nancy E. Rister

Williamson County Clerk

405 MLK Street, Box 14 Georgetown, Texas 78626

By: /S/Kathy Klingelberger, Deputy

3618

NOTICE TO CREDITORS

Notice is hereby given that original letters testamentary for the Estate of Ernest C. Morton a/k/a Ernest Charles Morton a/k/a Ernest Morton, deceased, were issued on August 13, 2025, in Cause No. 25-0723-CP4 pending in County Court at Law No. 4, Williamson County, Texas,

BRENDA UFFMAN MORTON

c/o Sandra M. Lefler / Brenda K. West

The Lefler Law Firm

1530 Sun City Blvd, Ste 119 Georgetown, Texas 78633

3619

NOTICE TO CREDITORS

Notice is hereby given that original letters testamentary for the Estate of Anette Lynn Snowden a/k/a Anette L. Snowden a/k/a Anette L. Strother a/k/a Anette Lynn Strother, deceased, were issued on August 13, 2025, in Cause No. 25-0863-CP4 pending in County Court at Law No. 4, Williamson County, Texas, to:

JAMES COY SNOWDEN

c/o Sandra M. Lefler / Brenda K. West

The Lefler Law Firm

1530 Sun City Blvd, Ste 119 Georgetown, Texas 78633

3620

CITATION BY PUBLICATION

THE STATE OF TEXAS COUNTY OF WILLIAMSON

TO ALL PERSONS INTERESTED IN THE ESTATE OF JERROD NEAL WORSHAM, DECEASED, Cause No. 25-0982-CP4, in County Court at Law #4 of Williamson County, 405 Martin Luther King Street, Georgetown, Texas 78626.

KELLI ELAINE WORSHAM, Applicant in the above numbered and entitled estate, filed on the 14th day of August, 2025 an APPLICATION FOR INDEPENDENT ADMINISTRATION AND LETTERS OF ADMINISTRATION AND APPLICATION TO DETERMINE HEIRSHIP of the said estate and requests that the said Court determine who are the heirs and only heirs of the said JERROD NEAL WORSHAM, DECEASED, and their respective shares and interest in such estate.

If this citation is not served within 90 days after the date of its issuance, it shall be returned unserved.

Issued and given under my hand and seal of office at Georgetown, Texas, this the 14th day of August, 2025.

Applicant’s Attorney:

Elizabeth McFarland 200 W 6th St, Suite 110 Georgetown, Texas 78626

Nancy E. Rister

Williamson County Clerk 405 MLK Street, Box 14 Georgetown, Texas 78626

By: /S/Brandi Dimler, Deputy

3622

NOTICE TO CREDITORS

Notice is given that original Letters Testamentary for the Estate of Cathryn J. Hubbard were issued on July 28, 2025, in Docket No. 25-0796-CP4, pending in the County Court at Law Number 4 of Williamson County, Texas, to Natalie Hubbard. All persons having claims against the estate, which is presently being administered, are required to submit them, within the time and manner prescribed by law, and before the estate is closed, addressed as follows:

c/o Natalie Hubbard

3909 Shady Valley Drive Arlington, Texas 76013

Dated August 15, 2025

/s/ Angela M. Dowdle

Angela M. Dowdle

Attorney for Executor of the Estate of Cathryn J. Hubbard

3634

You’ve been sued

CITATION BY PUBLICATION

Cause # 24-0240-F395

THE STATE OF TEXAS COUNTY OF WILLIAMSON

TO: Ludwin Mendez Chilel

AND TO ALL WHOM IT MAY CONCERN:

Respondent(s): GREETING

NOTICE TO RESPONDENT: “YOU HAVE BEEN SUED. You may employ an attorney. If you or your attorney do not file a written answer with the clerk who issued this citation by 10:00 am on the Monday next following the expiration of 20 days after the date you were served this citation and petition, a default judgment may be taken against you. In addition to filing a written answer with the clerk, you may be required to make initial disclosures to the other parties of this suit. These disclosures generally must be made no later than 30 days after you file your answer with the clerk. Find out more at TexasLawHelp.org”

** If posted at the courthouse door the written answer shall be filed by 10:00 AM on the Monday next following the expiration of 20 days following the 7th day of posting (STRIKE IF PUBLISHED).

The petition of YESENIA YOLANDA LOPEZ CAX, was filed in the 395th Judicial District Court of Williamson County, Texas on the 25th day of January, 2024, numbered 24-0240-F395 and entitled In The Interest Of X.A.A.M.L., A Child.

The suit requests relief as is more fully shown by the Petition on file in this suit.

The court has authority in this suit to render an order in the child’s/children’s interest that will be binding on you, including the termination of the Parent-child Relationship, the determination of paternity and the appointment of a conservator with authority to consent to the child’s/children’s adoption.

ISSUED AND GIVEN UNDER MY HAND AND SEAL of said Court at Williamson County, Texas on this the 30th day of July, 2025.

Attorney for Party requesting citation: Lisa David, District Clerk

Alejandra Martinez

8023 Vantage Drive, Suite 800 San Antonio, Texas 78230

PO Box 24, Georgetown, TX 78627 Williamson County, Texas

(512) 943-1212

BY: Heather Frazier Heather Frazier, Deputy

3511

Bids & Proposals

PUBLIC NOTICE

The Georgetown ISD will be accepting sealed bids for:

Vehicle Maintenance Repair, Services & Supplies - Bid #26-004, Closes 2:00pm, August 31, 2030

Solicitation is available on the District’s eBID electronic bidding system, website:

https://georgetownisd.ionwave.net/. Registration is required, at no charge, to access the bid documents.

3602

Williamson County and Cities Health District is requesting proposals

for a Public Health Strategic Advisor. Potential contractors may Register with WCCHD and locate detailed bid information in Solicitations. Proposals must be submitted by the due date and time specified. Late responses will not be accepted under any circumstances. Please visit www.wcchd.org/about/divisions.php for more information.

3629

Government Notices

NOTICE OF PUBLIC HEARING

ON THE 2025/2026 WILLIAMSON COUNTY BUDGET

Take notice that a public hearing on the proposed 2025/2026 Williamson County Budget will be held before the Commissioners Court of Williamson County, Texas, on Wednesday, September 3rd, 2025, at 1:00 o’clock pm, the place of such hearing being the Commissioners courtroom, 710 Main St, 2nd floor, Georgetown, Texas. (NOTE: The Williamson County Commissioners Court cancelled the previously called Budget Hearing that was originally set for Tuesday, August 26th, 2025 at 9:30 a.m. due to an error in the prior notice that was published and reset the Budget Hearing to be held at the time, date and location set forth above.)

And notice is hereby given of such hearing to all persons concerned in order that they may appear before said court at the time and place herein mentioned and to attend such hearing and to contend for or to protest the proposed 2025/2026 Williamson County budget, and all persons interested shall have the right to offer testimony to show that the proposed 2025/2026 county budget should or should not be so adopted. This budget will raise more property taxes than last year’s budget by $54,793,773, or 10.7%, and of that amount, $20,580,210 is tax revenue to be raised from new property added to the tax roll this year.

A copy of the budget shall be filed by the County Budget Officer in accordance with LGC 111.066. A copy of the adopted budget will be available for viewing in the County Clerk’s office, room BO 3 Research Division, located in the basement of the Justice Center Annex, 405 Martin Luther King Blvd., Georgetown, Texas. Online access to the budget will be available at Budget Overview | Williamson County, TX (wilcotx.gov)

For information regarding the budget please contact the Budget Officer’s office at 512-943-1551. Issued by order of the Williamson County Commissioners Court.

Steven Snell

County Judge

Williamson County, Texas

3628

New Laws

Ordinance caption that was approved at the 08/12/2025 Council Meeting

An Ordinance of the City Council of the City of Georgetown, Texas amending Section 1.12.030 of the Code of Ordinances relating to the adoption of an updated Future Mobility Plan, including updates to the Functional Transportation Plan, in accordance with Article I, Section 1.08 of the Georgetown City Charter and functional elements thereof; repealing conflicting ordinances and resolutions; including a severability clause; and establishing an effective date.

ORD2025-39

An Ordinance of the City Council of the City of Georgetown, Texas authorizing an annual service plan update and an update to the assessment roll for Parks at Westhaven Public Improvement District, in accordance with Chapter 372 of the Texas Local Government Code; repealing conflicting ordinances and resolutions; making such other findings and provisions related to the subject; and declaring an effective date.

ORD2025-40

An Ordinance of the City Council of the City of Georgetown, Texas Chapter 13.32 of the Code of Ordinance relating to Water and Wastewater Impact Fees to amend the definitions; amend the land use assumptions; amend the impact fee capital improvements plan for water and wastewater facilities; amend the water and wastewater impact fee amounts; amend the assessed water and wastewater fee history; including a severability clause; repealing conflicting ordinances and resolutions and establishing an effective date.

ORD2025-41

An Ordinance of the City Council of the City of Georgetown, Texas amending Chapter 12.46 of the Code of Ordinances relating to Transportation Impact Fees to amend the definitions; amending the land use assumptions; amending the transportation impact fee capital improvements plan; amending the service areas; amending the computation of impact fees; amending the transportation impact fee amounts; amending the assessed transportation impact fee history; including a severability clause; repealing conflicting ordinances and resolutions; and establishing an effective date.

3609

Booze News

Application has been made with the Texas Alcoholic Beverage Commission for a Mixed Beverage Permit and Food & Beverage Certificate by The Dugout Gametime Grill, LLC dba The Dugout Gametime Grill to be located at 401 Cypress Creek Road, Suite 600, Cedar Park, Williamson County, Texas. James Barrett Cox, Manager.

3584

An application has been made for a Wine Only Package Store for Mureed Group of Investors Inc., Texas Corporation, d/b/a 7-Eleven Convenience Store #36103B, located at 2680 Gattis School Rd, Round Rock, Williamson County, TX.

Said application made to the Texas Alcoholic Beverage Commission in accordance with the provisions of the Texas Alcoholic Beverage Code.

Mureed Group of Investors Inc. officers:

Shahid Thahim – President & Secretary

3621

Miscellanous

CAUSE No. 25-1265-C395 IN RE: NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

IN THE DISTRICT COURT 395th JUDICIAL DISTRICT WILLIAMSON COUNTY, TEXAS

NOTICE OF HEARING ON PETITIONERS’ PETITION FOR PRE-SUIT DISCOVERY

Please take notice that a hearing on Petitioners’, Nikolas Putman, Robert Schubert, and Matterhorn Express Pipeline, LLC, Verified Petition for Pre-Suit Discovery (the “Petition”) is set for hearing on: August 27, 2025, at 9:00 a.m., in person, in the 395th Judicial District Court of Williamson County, Texas. The Court’s address is 405 Martin Luther King Street, Georgetown, Texas 78626.

Pursuant to Rule 202.3(a) of the Texas Rules of Civil Procedure, this Notice is being served, together with a copy of Petitioners’ Petition, in accordance with Rule 21a on those persons Petitioners seek to depose and all persons Petitioners expect to have an adverse interest in a potential future suit.

Pursuant to Rule 202.3(a) of the Texas Rules of Civil Procedure, this Notice is also being published, together with a copy of Petitioners’ Petition.

Respectfully submitted,

Ross Molina Oliveros, P.C.

4118 Pond Hill Road, Suite 100 San Antonio, Texas 78231

(210) 249-3200 – Telephone

(210) 249-3201 – Facsimile

/s/ Ramon A. Molina

Ramon A. Molina, Attorney-in-Charge

State Bar No. 24032872

ramolina@rmolawfirm.com

Andrew Stephens

State Bar No. 24082559

astephens@rmolawfirm.com

ATTORNEYS FOR PETITIONERS,

NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

COMES NOW, Petitioners, Nickolas Putman (“Putman”), Robert Schubert (“Schubert”), and Matterhorn Express Pipeline, LLC (“Matterhorn” and collectively with Putman and Schubert as the “Petitioners”), filing this, their Verified Petition for Pre-Suit Discovery (the “Petition”) seeking: (1) to take written and/or oral depositions and (2) the production of relevant documents in anticipation of a future lawsuit and to fully investigate whether other potential claims or persons should be included in said suit, and would respectfully show the Court as follows: VERIFICATION

1. Pursuant to Rule 202.2(a), Petitioners attach to this Petition the verification and Affidavit of Nick Putman (the “Putman Affidavit”), as Petitioners’ Exhibit A. JURISDICTION & VENUE

2. This Court has jurisdiction over this matter under Rule 202 of the Texas Rules of Civil Procedure. A future suit, if filed, would have damages in excess of the Court’s minimal jurisdictional requirements. Venue is proper in Williamson County under Rule 202, since all or a substantial part of the events or omissions giving rise to any future claim or claims occurred in Williamson County and venue for this Petition may lie in the County of an anticipated suit.

PARTIES & SUBJECT MATTER

3. Petitioner, Nickolas Putman, is an individual with his primary residence and domicile located in Morehouse Parish County, Louisiana.

4. Petitioner, Robert Schubert, is an individual with his primary residence and domicile located in Kendall County, Texas.

5. Petitioner, Matterhorn Express Pipeline, LLC, is a Delaware limited liability company, and is authorized to transact business in the State of Texas.

6. Petitioners anticipate the institution of a suit against certain individuals, in which one or more of the Petitioners may be parties. Further, Petitioners seek to investigate potential claims they may have as part of the anticipated suit.

7. The subject matter of the anticipated action includes, but is not limited to, claims against an unknown individual who assaulted Putman and Schubert (the “Unknown Pilot”), while they were acting as agents of Matterhorn. Specifically, on February 20, 2024, Putman and Schubert were working directly on Matterhorn’s behalf and at its instruction to stake a recently acquired easement on property in Williamson County, Texas (the “Property”). The Property is owned by NMCV Taylor Property Investors, LLC, and Mr. Emory Stromberg is believed to have either been the lessee or the tenant at the time of the incident.

8. While Putman and Schubert were working on the Property, the Unknown Pilot intentionally assaulted them by flying low overhead and “crop dusting” the agents with pesticides and/or smoke. See Petitioners’ Exhibit A. After Putman and Schubert were assaulted, they immediately ran to their nearby truck. See Petitioners’ Exhibit A. Before Putman and Schubert got into the truck, the Unknown Pilot proceeded to fly overhead again, this time crop dusting the truck. See Petitioners’ Exhibit A.

9. After the assault, Putman and Schubert agents contacted their superiors and immediately sought medical attention and treatment. Id.

10. After being notified of its agents being assaulted, Matterhorn began investigating the incident and reached out to Mr. Stromberg to obtain the necessary information to identify the Unknown Pilot and the pesticides and/or smoke that Putman and Schubert were sprayed with. Mr. Stromberg admitted he was familiar with the incident and admitted to having personal knowledge of the assault, although he claims the Unknown Pilot “only” used smoke—not pesticides. Unfortunately, despite Matterhorn’s request, Mr. Stromberg refused to provide any information on the identity of the Unknown Pilot.

11. Upon information and belief, the Unknown Pilot and/or Mr. Stromberg acquired the chemicals to be used to crop-dust the Property from Helena Agri-Enterprises, LLC (“Helena”), which has a location in nearby Taylor, Texas.

12. Since the assault, Putman has experienced breathing and coughing problems. See Petitioners’ Exhibit A.

13. The pre-suit discovery requested in this Petition is necessary to prevent a failure or delay of justice. Specifically, Petitioners must be afforded the opportunity to identify the Unknown Pilot to bring suit. Further, the importance of allowing Petitioners to conduct pre-suit discovery on these narrow issues outweighs the burden or expense of the procedure and, at the very least, will allow Petitioners to fully evaluate potential claims and thereby prevent filing unnecessary claims

and naming unnecessary defendants.

14. Petitioners expect the following unknown person to have adverse interests in any future claim or suit:

a. The Unknown Pilot, a.k.a. John Doe. The Unknown Pilot crop dusted Putman and Schubert while they were acting on behalf of and at Matterhorn’s direction as its

agents and were within the scope of their work. Based on conversations with Mr. Stromberg, the Unknown Pilot is believed to be “a professional pilot” that has “flown for many years in [the Williamson County] area.” Despite Matterhorn’s requests, Mr. Stromberg has refused to identify the Unknown Pilot, necessitating, in part, this Petition.

15. Despite diligent inquiry, Petitioners are unable to ascertain the name, address, or telephone number of the Unknown Pilot. Accordingly, Petitioners will provide the statutorily required notice to the Unknown Pilot via publication pursuant to Rule 202. See TEX. R. CIV. P. 202.3(b).

REQUESTED DISCOVERY

16. Petitioners seek to depose, via written and/or oral depositions, and obtain documents from, via discovery requests, the following persons and/or entities:

a. Mr. Emory Stromberg:

1721 County Road 368

Taylor, Texas 76574

(512) 914-2826

Petitioners expect to elicit from Mr. Stromberg, by deposition or the production of documents, the identity of the Unknown Pilot and information concerning the assault of Putman and Schubert, and the chemicals used therein. Petitioners also expect to ascertain whether the Unknown Pilot acted within the scope of his employment and whether any other persons were involved in the Unknown Pilot’s assault of Putman and Schubert.

While Petitioners do not presently anticipate any claims against Mr. Stromberg individually, in an abundance of caution and based on his refusal to willingly provide information to concerning the identity of the Unknown Pilot, Petitioners note that Mr. Stromberg may take the position that his interest is adverse to Petitioners.

b. Helena Agri-Enterprises, LLC:

c/o C. T. Corporation System, as registered agent

1999 Bryan St., Suite 900

Dallas, Texas 75201-3136

Helena is a Delaware limited liability company and is registered to, and is currently, doing business in the State of Texas.

Petitioners expect to elicit from Helena, by deposition or the production of documents, information concerning the chemical composition of, and health and safety warnings associated with chemicals sold to the Unknown Pilot. Petitioners also expect to ascertain the identity of the Unknown Pilot.

17. Petitioners desire to obtain the expected testimony and documents from Mr. Stromberg and Helena to fully investigate claims to be made against the Unknown Pilot and to discover information directly related to the health and safety of Putman and Schubert. Matterhorn intends to initially seek the information it needs from Mr. Stromberg and Helena through depositions on written questions and requests for production. If additional information is needed thereafter, Petitioners reserve the right to take the oral depositions of Mr. Stromberg and/or a representative of Helena1.

REQUEST FOR RELIEF

18. For the reasons above, Petitioners request the Court set this Petition for a hearing, that notice be provided to the Unknown Pilot, Mr. Stromberg, and Helena as prescribed by the Rules, and that, after the hearing, the Court order and permit the pre-suit discovery contemplated and sought as part of this Petition to be sent to Mr. Stromberg and Helena, including depositions on written questions and requests for production, and, if necessary, oral depositions. To the extent necessary, Petitioners hereby attach drafts of their anticipated Notices of Deposition by Written Questions and corresponding Requests for Production hereto collectively as Petitioners’ Exhibits B-1, B-2, B-3, and B-4.

1 To the extent it becomes clear that Petitioners needs to conduct additional pre-suit discovery directed to the Unknown Pilot, they will amend this Petition at that time and will resubmit the Petition for consideration by the Court.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Petitioners respectfully request the Court to set this Petition for hearing and, after the hearing, permit pre-suit discovery to be sent to Mr. Stromberg and Helena, including depositions on written questions, requests for production, and, if necessary, oral depositions.

Petitioners also pray for such other and further relief to which they may be justly entitled, in law or in equity.

Respectfully submitted,

ROSS MOLINA OLIVEROS, P.C.

4118 Pond Hill Road, Suite 100

San Antonio, Texas 78231

(210) 249-3200 – Telephone

(210) 249-3201 – Facsimile

By: /s/ Ramon A. Molina

Ramon A. Molina, Attorney-in-Charge

State Bar No. 24032872

ramolina@rmolawfirm.com

Andrew Stephens

State Bar No. 24082559

astephens@rmolawfirm.com

ATTORNEYS FOR PETITIONERS,

NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

EXHIBITA

EXHIBIT A

AFFIDAVIT OF NICK PUTMAN

STATE OF Louisiana

PARISH of West Carroll

Before me, the undersigned authority, personally appeared Nickolas Putman who, being by me duly sworn, stated as follows:

I. “My name is Nickolas Putman I am over 21 years of age, am of sound mind, and I am fully competent to make this affidavit. The facts set forth in this affidavit are within my personal knowledge and are true and correct.

2. On February 20, 2024, I was working for TableRock Survey near Taylor, Texas with Robert Schubert to stake the Right of Way (ROW) for the Matterhorn Pipeline on property owned by NMCV Taylor Property Investors, LLC (the “Property’”’).

3. The ROW on the Property is located along the Northern and Eastern boundaries. A depiction of the ROW on the Property is attached hereto as Exhibit 1.

4. When we arrived that morning, we parked my truck within the ROW on the Property and started measuring and staking the Northern portion of the ROW.

5. After about 1,000 feet, Robert and I noticed a crop-dusting plane, which began spraying the South end of the Property.

6. As we finished our work on the Northern end and turned South to move along the Eastern portion of the ROW, the crop-dusting plane flew across the Property and flew over our heads really low to the ground. The plane then turned around and flew back over us and sprayed us with something before flying to my truck and spraying it as well.

7. After spraying my truck, the crop-dusting plane immediately flew away.

8. I do not know what the crop-dusting plane sprayed me, Robert, or my truck with, but it burned my eyes and skin and hurt to breathe in.

9. Once the smoke cleared, Robert and I immediately got inside my truck. Then I called my supervisor to let him know what happened, and he told me to let him make a call and he would call me back.

10. While I was waiting for my supervisor to call me back, Mr. Stromberg drove his Jeep onto the Property and stopped in front of my truck and got out and began accusing us of calling the police on the pilot of the crop-dusting plane.

as I told Mr. Stromberg that we did not call the police, only my supervisor and that we were waiting for him to call us back. Mr. Stromberg then drove away.

12. My supervisor then called back and Robert and I were instructed to leave the Property, go change our clothes, and to visit a clinic in Lampasas, Texas.

13. Since the initial visit to the clinic, I have been to the Emergency Room numerous times with problems breathing and coughing, and none of the doctors were able to determine why I was having problems. Two of the visits were to the Morehouse ER in Bastrop, Louisiana.

14. I’ve visited my regular doctor in Start, Louisiana and they ran tests and said I did not have the flu or COVID and that they couldn’t understand why I was having issues breathing.

Further affiant sayeth naught.”

/s/ NICKOLAS PUTMAN

NICKOLAS PUTMAN

SWORN TO AND SUBSCRIBED before me on the 13 day of May2025.

/s/ Patrician H. Copes #041017

Notary Public, State of Louisiana

EXHIBIT B-1

PETITIONERS’ EXHIBIT B-1

IN RE: NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC IN THE DISTRICT COURT ___ JUDICIAL DISTRICT WILLIAMSON COUNTY, TEXAS

PETITIONERS’ PRE-SUIT

REQUESTS FOR PRODUCTION TO EMORY STROMBERG

To: Mr. Emory Stromberg, 1721 County Road 368, Taylor, Texas 76574 Pursuant to Rule 196 of the Texas Rules of Civil Procedure and the Court’s authorization of pre-suit discovery in the above referenced cause, Petitioners, Nickolas Putman (“Putman”), Robert Schubert (“Schubert”), and Matterhorn Express Pipeline, LLC (“Matterhorn” and collectively with Putman and Schubert as the “Petitioners”) serve these Pre-Suit Requests for Production. Please produce all requested documents as they are kept in the ordinary course of business, organized, and labeled to correspond with categories in each request, for inspection and copying, not more than thirty days after service, at the law offices of ROSS MOLINA OLIVEROS, P.C., 4118 Pond Hill Rd., Suite 100, San Antonio, Texas 78231.

Respectfully submitted,

ROSS MOLINA OLIVEROS, P.C.

4118 Pond Hill Road, Suite 100 San Antonio, Texas 78231

(210) 249-3200 – Telephone (210) 249-3201 – Facsimile

By: /s/ Ramon A. Molina

Ramon A. Molina, Attorney-in-Charge

State Bar No. 24032872

ramolina@rmolawfirm.com

Andrew Stephens

State Bar No. 24082559

astephens@rmolawfirm.com

ATTORNEYS FOR PETITIONERS, NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

PETITIONERS’ EXHIBIT B-1

CERTIFICATE OF SERVICE

I hereby certify that on this ___ day of ___________________ 2025, this document was served by the method indicated, pursuant to Rule 21a of the Texas Rules of Civil Procedure:

Emory Stromberg 1721 County Road 368 Taylor, Texas 76574 FIRST CLASS RRR#

(512) 914-2826

/s/ Ramon A. Molina

Ramon A. Molina

PETITIONERS’ EXHIBIT B-1

PRE-SUIT REQUESTS FOR PRODUCTION

A. Instructions

1. Serve a written response to each of the attached Requests for Production within thirty (30) days following service. With respect to each item or category of items requested, state whether: (1) production and/or inspection will be permitted when and as requested; (2) the requested items are being served with the response; or (3) no responsive items have been identified, after a diligent search.

2. With respect to production, produce all responsive documents in your possession, custody or control with the responses or at the offices of the undersigned counsel within thirty (30) days following service of the Requests for Production.

3. These Requests are continuing in nature and require supplementation or amendment as soon as practicable if you or your attorney obtain information which reveals that your answers were incorrect or incomplete when made or that your answers are no longer correct or complete.

4. Your failure to respond to these Requests as required by the Texas Rules of Civil Procedure in the manner and within the time required may result in entry of judgment against you, assessment of attorneys’ fees against you, or other sanctions as determined by the Court.

5. Documents produced pursuant to these Requests should be tendered either in the precise form or manner as they are kept in the usual course of business or organized and labeled to correspond with the categories in the Requests to which they respond.

6. The requested documents include those within your possession, custody or control. If any document requested herein has been destroyed or is no longer in your possession, custody or control, describe in detail the circumstances of and reasons for such loss of possession or destruction, identify the current location of the document and/or who has current possession, custody or control, and produce all documents which relate to either the circumstances or the reasons for such loss of possession or destruction.

7. If any document responsive to a Request, as requested herein, is withheld under claim of privilege, pursuant to TEX. R. CIV. P. 193.3, provide the following information concerning the same: (1) that the document responsive to the Request has been withheld; (2) Request to which the information or document relates; (3) the specific privilege or privileges asserted for each item or group of items withheld; and (4) without revealing the privileged information itself or otherwise waiving the privilege, describe the information or documents withheld sufficiently to allow the assessment of the applicability of the privilege.

8. Unless otherwise stated within a Request, no Request herein seeks documents, tangible things or information discoverable exclusively under Rules 194.2(f) or 195 pertaining to testifying experts. These Requests do, however, apply to (i) any non privileged consulting experts, and (ii) any documents, tangible things and information that you discovered, prepared and/or possess independently of a testifying expert, even if a testifying expert also discovered, prepared and/or possesses them.

B. Definitions

The following words have the following meanings, unless the context requires otherwise:

1. The term “Petitioners” as used herein shall collectively mean Petitioners, Nickolas Putman, Robert Schubert, and Matterhorn Express Pipeline, LLC and, when applicable, their agents, representatives, officers, directors, employees, partners, corporate agents, subsidiaries, or affiliates.

2. “Mr. Stromberg,” “You,” and “Your” collectively mean and refer to the above-named person on whom these requests have been served, and any person acting on their behalf.

3. The term “Property” is defined in Petitioners’ Verified Petition for Pre-Suit Discovery, and any supplements or amendments thereto, and refers to the tract of land where the crop dusting incident took place in Williamson County, Texas.

4. The term “document” is used herein in its broadest sense to include any medium upon or with which information is recorded or preserved which belongs to, or is in or subject to the possession, custody, or control of, any of the parties named hereinabove, by whomever generated or received, including without limitation: writings; printings; drawings; graphs; charts; notes; typewritings; photographs; slides; motion pictures; videotapes or cassettes; phonograph records; tape, video or other mechanical recordings; computer records, information storage devices, disks, or printouts; brochures; pamphlets; maps; surveys; calendars; contracts; interoffice communications; telephone recordings; ledgers; books; statements of account; journals; notices; letters; catalogs; canceled checks; bank statements; invoices; bills; diaries; purchase orders; memoranda of telephone communications; telegrams; telexes or “TWX’s”; telecopies; drafts or preliminary versions of the foregoing; communications to or from any governmental or law enforcement sub division, officer, or agency; and, any other instrument, writing, recording, or data compilation of any nature whatsoever, including any carbon, photographic, microfilm, or other type of copy of such items, if such copy is different from the original by reasons of any markings, additions, commentaries, revisions, deletions, or substitutions. The documents requested include any responsive data or information that exists in electronic or magnetic form and any such data or information should be produced in the electronic or magnetic form in which it exists.

5. The term “person” as used herein shall mean and include an individual, sole proprietorship, association, firm, partnership, joint venture, corporation, board, committee, agency, commission, or any other legal entity of any type for any purpose, whether public or private.

6. The terms “relating,” “related,” “reflecting,” or “evidencing,” when used in referencing a certain subject or thing as used herein, shall mean and include to reflect, to evidence, to mention, to discuss, to describe, to explain, to embody, to constitute, or to include that subject or thing.

7. The term “or” as used herein shall mean and include “and” or “and/or.”

8. The term “all” as used herein shall mean “any” and “all.”

9. The term “including”, as used herein, shall mean “including, but not limited to.”

10. The terms “fact” and “facts” as used herein shall include, without limitation, every relevant matter, occurrence, act, event, transaction, occasion, meeting, document, instance, circumstance, recitation, writing, or other happening.

11. The term “communication” as used herein is used in its broadest sense and shall mean oral conversations, whether telephone or face-to-face, discussions, meetings, conferences, speeches and hearings, written communications, whether letter, facsimile, or electronic transmission, and internal and external communications, and shall include both word and visual communication of any kind whatsoever.

12. The term “Unknown Pilot” is defined in Petitioners’ Verified Petition for Pre-Suit Discovery.

13. The term “Relevant Time Frame” as used herein shall mean from February 1, 2024 to the present.

14. Certain other terms may be defined within the requests for documents herein.

C. Requests for Production

Request for Production No. 1: Produce all documents and communications between you and the Unknown Pilot during the Relevant Time Frame regarding the Property, work to be performed on the Property, and concerning the events of February 20, 2024 as set forth in Petitioners’ Verified Petition for Pre-Suit Discovery.

Response:

Request for Production No. 2: Produce all documents concerning payments made by You to the Unknown Pilot during the Relevant Time Frame.

Response:

Request for Production No. 3: Produce all documents evidencing any pesticides or other products purchased for the purpose of crop-dusting the Property during the Relevant Time Frame. This Request includes, but is not limited to, any available health and safety related information or warnings for said chemicals or products.

Response:

Request for Production No. 4: Produce all documents evidencing the chemicals or products used on the Property to treat crops via crop-dusting during the Relevant Time Frame, regardless of whether said chemicals or products were purchased during the Relevant Time Frame. This Request includes, but is not limited to, any available health and safety related information or warnings for said chemicals or products.

Response:

EXHIBIT B-2

PETITIONERS’ EXHIBIT B-2

CAUSE NO. _______________________ IN RE: NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

IN THE DISTRICT COURT __ JUDICIAL DISTRICT WILLIAMSON COUNTY, TEXAS

PETITIONERS’ PRE-SUIT

DEPOSITION ON WRITTEN QUESTIONS TO EMORY STROMBERG To: Mr. Emory Stromberg, 1721 County Road 368, Taylor, Texas 76574 PLEASE TAKE NOTICE that under Texas Rule of Civil Procedure 200, Petitioners, Nickolas Putman (“Putman”), Robert Schubert (“Schubert”), and Matterhorn Express Pipeline, LLC (“Matterhorn” and collectively with Putman and Schubert as the “Petitioners”), will take the deposition by written questions of Mr. Emory Stromberg (“Deponent”), pursuant to the Court’s authorization of pre-suit discovery in the above referenced cause, at __:00 __.m. on __________ __, 2024, at the offices of ROSS MOLINA OLIVEROS, PC, 4118 Pond Hill Road, Ste. 100, San Antonio, Texas, or on a date and at a location mutually agreed upon by the Deponent and Petitioners. Deponent will be required to answer the questions listed in Exhibit B, attached hereto and made a part hereof before a certified court reporter authorized to take depositions in Texas.

Respectfully submitted,

ROSS MOLINA OLIVEROS, P.C.

4118 Pond Hill Road, Suite 100 San Antonio, Texas 78231

(210) 249-3200 – Telephone (210) 249-3201 – Facsimile

By: /s/ Ramon A. Molina

Ramon A. Molina, Attorney-in-Charge

State Bar No. 24032872

ramolina@rmolawfirm.com

Andrew Stephens

State Bar No. 24082559

astephens@rmolawfirm.com

ATTORNEYS FOR PETITIONERS,

NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

PETITIONERS’ EXHIBIT B-2

CERTIFICATE OF SERVICE

I hereby certify that on this ___ day of ___________________ 2025, this document was served by the method indicated, pursuant to Rule 21a of the Texas Rules of Civil Procedure:

Emory Stromberg

1721 County Road 368 Taylor, Texas 76574

(512) 914-2826

FIRST CLASS MAIL RRR#

/s/ Ramon A. Molina

Ramon A. Molina

PETITIONERS’ EXHIBIT B-2

EXHIBIT “A”

Definitions and Instructions for Written Questions under Exhibit “B” The following words have the following meanings, unless the context requires otherwise:

2. “Mr. Stromberg,” “You,” and “Your” collectively mean and refer to the above-named person on whom these requests have been served, and any person acting on their behalf.

7. The term “or” as used herein shall mean and include “and” or “and/or.”

8. The term “all” as used herein shall mean “any” and “all.”

9. The term “including”, as used herein, shall mean “including, but not limited to.”

12. The term “Unknown Pilot” is defined in Petitioners’ Verified Petition for Pre-Suit Discovery.

13. The term “Relevant Time Frame” as used herein shall mean from February 1, 2024 to the present.

14. Certain other terms may be defined within the requests for documents herein.

EXHIBIT “B”

CAUSE NO. _______________________

IN RE: NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

IN THE DISTRICT COURT ___ JUDICIAL DISTRICT WILLIAMSON COUNTY, TEXAS

Written Questions

1. Please state your full name, occupation, and address.

Response:

_______________________________________________________________________ _______________________________________________________________________ _______________________________________________________________________

2. Are you of sound mind, capable of answering these questions, signing the verification, and personally acquainted with the facts therein?

Response:

3. Please state the full name, occupation, employer, address, and any other available contact information (i.e. email, phone number) for the Unknown Pilot.

Response:

4. Please briefly summarize the substance of any communications you had with the Unknown Pilot during the Relevant Time Frame concerning the events of February 20, 2024 as set forth in Petitioners’ Verified Petition for Pre-Suit Discovery.

Response:

5. Please identify the chemicals or products purchased during the Relevant Time Frame for use on the Property to treat crops via crop-dusting. Please include, as part of Your Response, any available health and safety related information or warnings for any identified chemicals or products.

Response:

6. Please identify the chemicals or products used on the Property to treat crops via crop dusting during the Relevant Time Frame, regardless of whether said chemicals or products were purchased during the Relevant Time Frame. Please include, as part of Your Response, any available health and safety related information or warnings for any identified chemicals or products.

Response:

7. Please identify any person You have communication with concerning the events of February 20, 2024 as set forth in Petitioners’ Verified Petition for Pre-Suit Discovery. Please include, as part of your Response, the contact information for person identified as well as a brief description of the general substance of any communications.

Response:

8. Please identify your relationship with the Unknown Pilot.

Response:

SIGNED the _____ day of ________________, 2025.

__________________________________

Name of Deponent

VERIFICATION

Before me, the undersigned notary, on this day, appeared ______________, a person whose identity is known to me. After I administered an oath to _____________, he testified:

“My name is _____________. I am capable of making this verification. I verify that the responses contained herein are true and correct to the best of my knowledge.”

SWORN TO AND SUBSCRIBED before me by _____________, on this _______ day of __________________, 2025, to certify which witness my hand and official seal.

________________________________

Notary Public, State of Texas

Printed name:

____________________________

Commission Expires

EXHIBIT B-3

PETITIONERS’ EXHIBIT B-3

CAUSE NO. _______________________

IN RE: NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

IN THE DISTRICT COURT ___ JUDICIAL DISTRICT WILLIAMSON COUNTY, TEXAS

PETITIONER’S PRE-SUIT

REQUESTS FOR PRODUCTION TO HELENA AGRI-ENTERPRISES, LLC

To: Helena Agri-Enterprises, LLC, c/o C. T. Corporation System, as registered agent, 1999 Bryan St., Suite 900, Dallas, Texas 75201-3136

Pursuant to Rule 196 of the Texas Rules of Civil Procedure and the Court’s authorization of pre-suit discovery in the above referenced cause, Petitioners, Nickolas Putman (“Putman”), Robert Schubert (“Schubert”), and Matterhorn Express Pipeline, LLC (“Matterhorn” and collectively with Putman and Schubert as the “Petitioners”), serves these Pre-Suit Requests for Production. Please produce all requested documents as they are kept in the ordinary course of business, organized, and labeled to correspond with categories in each request, for inspection and copying, not more than thirty days after service, at the law offices of ROSS MOLINA OLIVEROS, P.C., 4118 Pond Hill Rd., Suite 100, San Antonio, Texas 78231.

Respectfully submitted,

ROSS MOLINA OLIVEROS, P.C.

4118 Pond Hill Road, Suite 100 San Antonio, Texas 78231

(210) 249-3200 – Telephone (210) 249-3201 – Facsimile

By: /s/ Ramon A. Molina

Ramon A. Molina, Attorney-in-Charge

State Bar No. 24032872

ramolina@rmolawfirm.com

Andrew Stephens

State Bar No. 24082559

astephens@rmolawfirm.com

ATTORNEYS FOR PETITIONERS,

NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

PETITIONERS’ EXHIBIT B-3

CERTIFICATE OF SERVICE

I hereby certify that on this ___ day of __________________ 2025, this document was served by the method indicated, pursuant to Rule 21a of the Texas Rules of Civil Procedure:

Helena Agri-Enterprises, LLC: c/o C. T. Corporation System, as registered agent 1999 Bryan St., Suite 900 Dallas, Texas 75201-3136

FIRST CLASS MAIL RRR#

/s/ Ramon A. Molina

Ramon A. Molina

PETITIONERS’ EXHIBIT B-3

PRE-SUIT REQUESTS FOR PRODUCTION

A. Instructions

B. Definitions

The following words have the following meanings, unless the context requires otherwise:

2. “Helena,” “You,” and “Your” collectively mean and refer to the above-named entity on whom these requests have been served, and any person acting on its behalf.

3. “Mr. Stromberg” and “Emory Stromberg” collectively mean and refer to Mr. Emory Stromberg, located at 1721 County Road 368, Taylor, Texas 76574.

4. The term “Property” is defined in Petitioners’ Verified Petition for Pre-Suit Discovery, and any supplements or amendments thereto, and refers to the tract of land where the crop dusting incident took place in Williamson County, Texas.

5. The term “document” is used herein in its broadest sense to include any medium upon or with which information is recorded or preserved which belongs to, or is in or subject to the possession, custody, or control of, any of the parties named hereinabove, by whomever generated or received, including without limitation: writings; printings; drawings; graphs; charts; notes; typewritings; photographs; slides; motion pictures; videotapes or cassettes; phonograph records; tape, video or other mechanical recordings; computer records, information storage devices, disks, or printouts; brochures; pamphlets; maps; surveys; calendars; contracts; interoffice communications; telephone recordings; ledgers; books; statements of account; journals; notices; letters; catalogs; canceled checks; bank statements; invoices; bills; diaries; purchase orders; memoranda of telephone communications; telegrams; telexes or “TWX’s”; telecopies; drafts or preliminary versions of the foregoing; communications to or from any governmental or law enforcement sub division, officer, or agency; and, any other instrument, writing, recording, or data compilation of any nature whatsoever, including any carbon, photographic, microfilm, or other type of copy of such items, if such copy is different from the original by reasons of any markings, additions, commentaries, revisions, deletions, or substitutions. The documents requested include any responsive data or information that exists in electronic or magnetic form and any such data or information should be produced in the electronic or magnetic form in which it exists.

6. The term “person” as used herein shall mean and include an individual, sole proprietorship, association, firm, partnership, joint venture, corporation, board, committee, agency, commission, or any other legal entity of any type for any purpose, whether public or private.

7. The terms “relating,” “related,” “reflecting,” or “evidencing,” when used in referencing a certain subject or thing as used herein, shall mean and include to reflect, to evidence, to mention, to discuss, to describe, to explain, to embody, to constitute, or to include that subject or thing.

8. The term “or” as used herein shall mean and include “and” or “and/or.” 9. The term “all” as used herein shall mean “any” and “all.”

10. The term “including”, as used herein, shall mean “including, but not limited to.”

11. The terms “fact” and “facts” as used herein shall include, without limitation, every relevant matter, occurrence, act, event, transaction, occasion, meeting, document, instance, circumstance, recitation, writing, or other happening.

12. The term “communication” as used herein is used in its broadest sense and shall mean oral conversations, whether telephone or face-to-face, discussions, meetings, conferences, speeches and hearings, written communications, whether letter, facsimile, or electronic transmission, and internal and external communications, and shall include both word and visual communication of any kind whatsoever.

13. The term “Unknown Pilot” is defined in Petitioners’ Verified Petition for Pre-Suit Discovery.

14. The term “Relevant Time Frame” as used herein shall mean from February 1, 2024 to the present.

15. Certain other terms may be defined within the requests for documents herein.

C. Requests for Production

Response:

Request for Production No. 2: Produce all documents and communications between you and Mr. Stromberg during the Relevant Time Frame regarding the Property, work to be performed on the Property, and concerning the events of February 20, 2024 as set forth in Petitioners’ Verified Petition for Pre-Suit Discovery.

Response:

Request for Production No. 3: Produce all documents evidencing the sale (i.e. tickets, receipts, etc.) of any chemicals or products generally intended for or related to crop-dusting during the Relevant Time Frame to the Unknown Pilot.

Response:

Request for Production No. 4: Produce copies all associated labels, safety data sheets, and other information regarding health and safety warning associated with any chemicals or products generally intended for or related to crop-dusting sold to the Unknown Pilot during the Relevant Time Frame.

Response:

Request for Production No. 5: Produce all documents evidencing the sale (i.e. tickets, receipts, etc.) of any chemicals or produced generally intended for or related to crop-dusting during the Relevant Time Frame to Mr. Stromberg.

Response:

Request for Production No. 6: Produce copies all associated labels, safety data sheets, and other information regarding health and safety warning associated with any chemicals or products generally intended for or related to crop-dusting sold to the Unknown Pilot during the Relevant Time Frame.

Response:

EXHIBIT B-4

PETITIONERS’ EXHIBIT B-4

CAUSE NO. _______________________

IN RE: NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

IN THE DISTRICT COURT 395th JUDICIAL DISTRICT WILLIAMSON COUNTY, TEXAS

PETITIONERS’ PRE-SUIT

DEPOSITION ON WRITTEN QUESTIONS TO HELENA AGRI-ENTERPRISES, LLC

To: Helena Agri-Enterprises, LLC, c/o C. T. Corporation System, as registered agent, 1999 Bryan St., Suite 900, Dallas, Texas 75201-3136

PLEASE TAKE NOTICE that under Texas Rule of Civil Procedure 200, Petitioners, Nickolas Putman (“Putman”), Robert Schubert (“Schubert”), and Matterhorn Express Pipeline, LLC (“Matterhorn” and collectively with Putman and Schubert as the “Petitioners”), will take the deposition by written questions of an authorized representative or custodian of records for Helena Agri-Enterprises, LLC (“Deponent”), pursuant to the Court’s authorization of pre-suit discovery in the above referenced cause, at __:00 __.m. on _______________ __, 2025, at the offices of ROSS MOLINA OLIVEROS, PC, 4118 Pond Hill Road, Ste. 100, San Antonio, Texas, or on a date and at a location mutually agreed upon by the Deponent and Petitioners. Deponent will be required to answer the questions listed in Exhibit B, attached hereto and made a part hereof before a certified court reporter authorized to take depositions in Texas.

Respectfully,

ROSS MOLINA OLIVEROS, P.C.

4118 Pond Hill Road, Suite 100 San Antonio, Texas 78231

(210) 249-3200 – Telephone (210) 249-3201 – Facsimile

By: /s/ Ramon A. Molina

Ramon A. Molina, Attorney-in-Charge

State Bar No. 24032872

ramolina@rmolawfirm.com

Andrew Stephens

State Bar No. 24082559

astephens@rmolawfirm.com

ATTORNEYS FOR PETITIONERS,

NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

PETITIONERS’ EXHIBIT B-4

CERTIFICATE OF SERVICE

I hereby certify that on this ___ day of __________________2025, this document was served by the method indicated, pursuant to Rule 21a of the Texas Rules of Civil Procedure:

Helena Agri-Enterprises, LLC: c/o C. T. Corporation System, as registered agent 1999 Bryan St., Suite 900 Dallas, Texas 75201-3136

FIRST CLASS MAIL RRR#

/s/ Ramon A. Molina

Ramon A. Molina

PETITIONERS’ EXHIBIT B-4

EXHIBIT “A”

Definitions and Instructions for Written Questions under Exhibit “B” The following words have the following meanings, unless the context requires otherwise:

2. “Helena,” “You,” and “Your” collectively mean and refer to the above-named entity on whom these requests have been served, and any person acting on its behalf.

3. “Mr. Stromberg” and “Emory Stromberg” collectively mean and refer to Mr. Emory Stromberg, located at 1721 County Road 368, Taylor, Texas 76574.

8. The term “or” as used herein shall mean and include “and” or “and/or.”

9. The term “all” as used herein shall mean “any” and “all.”

10. The term “including”, as used herein, shall mean “including, but not limited to.”

13. The term “Unknown Pilot” is defined in Petitioners’ Verified Petition for Pre-Suit Discovery.

14. The term “Relevant Time Frame” as used herein shall mean from February 1, 2024 to the present.

15. Certain other terms may be defined within the requests for documents herein.

PETITIONERS’ EXHIBIT B-4

EXHIBIT “B”

CAUSE NO. _______________________

IN RE: NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

IN THE DISTRICT COURT ___ JUDICIAL DISTRICT WILLIAMSON COUNTY, TEXAS

Written Questions:

1. Please state your full name, occupation, and address.

Response:

2. Are you of sound mind, capable of answering these questions, signing the verification, and personally acquainted with the facts therein?

Response:

3. Please state the full name, occupation, employer, address, and any other available contact information (i.e. email, phone number) for the Unknown Pilot.

Response:

4. Please briefly summarize the substance of any communications you had with the Unknown Pilot during the Relevant Time Frame concerning: (1) the events of February 20, 2024 as set forth in Petitioners’ Verified Petition for Pre-Suit Discovery and/or (2) the sale of any products to the Unknown Pilot that are generally intended for or related to crop-dusting.

Response:

_______________________________________________________________________ _______________________________________________________________________5. Please briefly summarize the substance of any communications you had with Mr. Stromberg during the Relevant Time Frame concerning: (1) the events of February 20, 2024 as set forth in Petitioners’ Verified Petition for Pre-Suit Discovery and/or (2) the sale of any products to Mr. Stromberg that are generally intended for or related to crop-dusting.

Response:

6. Please identify the chemicals or products sold to the Unknown Pilot during the Relevant Time Frame for use on the Property to treat crops via crop-dusting. Please include, as part of Your Response, any available health and safety related information or warnings for any identified chemicals or products.

Response:

7. Please identify the chemicals or products sold to Mr. Stromberg during the Relevant Time Frame for use on the Property to treat crops via crop-dusting. Please include, as part of Your Response, any available health and safety related information or warnings for any identified chemicals or products.

Response:

8. Please identify the chemicals or products used on the Property to treat crops via crop dusting during the Relevant Time Frame, regardless of whether said chemicals or products were purchased during the Relevant Time Frame. Please include, as part of Your Response, any available health and safety related information or warnings for any identified chemicals or products.

Response:

_______________________________________________________________________ _______________________________________________________________________ _____________ _______________________________________________________________________

9. Please identify any person You have communicated with concerning the events of February 20, 2024 as set forth in Petitioners’ Verified Petition for Pre-Suit Discovery. Please include, as part of your Response, the contact information for person identified as well as a brief description of the general substance of any communications.

Response:

_______________________________________________________________________ _________________________________________________________

SIGNED the _____ day of ________________, 2025.

__________________________________

Name of Deponent

PETITIONERS’ EXHIBIT B-4

VERIFICATION

Before me, the undersigned notary, on this day, appeared ______________, a person whose identity is known to me. After I administered an oath to _____________, he testified:

“My name is _____________. I am capable of making this verification. I verify that the responses contained herein are true and correct to the best of my knowledge.”

SWORN TO AND SUBSCRIBED before me by _____________, on this _______ day of __________________, 2025, to certify which witness my hand and official seal.

________________________________

Notary Public, State of Texas

Printed name:

____________________________

Commission Expires

Automated Certificate of eService

This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Ronee Gomez on behalf of Ramon Molina

Bar No. 24032872

rgomez@rmolawfirm.com

Envelope ID: 101449430

Filing Code Description: Petition

Filing Description: Petitioners’ Verified Petition for Pre-Suit Discovery -EV# 101449430

Status as of 5/30/2025 4:00 PM CST

3531

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