Thread: Don Allen Holbrook IEDC Rogue Former Member / Jeff Finkle Orchestrates Cover-up

It appears the Front Sight deal in Pahrump may be dead in the water. A source shares that Nye County will not support the project. Without the support of the county this deal cannot go forward, unless of course Front Sight will finance everything. The city of Pahrump can only bond for sewers, so there will be no money for that screwball deal. So much for all of Don Allen Holbrook's expertise! Bye, bye Holbrook!

Soapboxmom

New Caney Dino Park Discussion & Rumors


COMMENTS

Comment by: on Aug. 18th, 2012 - 8:55am
Putting aside all the lawsuits, bickering and blah, blah blah, the results speak for themselves. Show me ANY progress. Please. Anything? A shovel of dirt? Anything? No, despite the money spent and pretty pictures passed around NOTHING has happened! Those results speak for themselves. Nobody can argue with that point. If you want proof, cover yourself with some decent insect repellent and go look. I think everyone wants this park built, but nobody involved has produced anything to show for money spent. I feel bad for Don Lessem. He deserves better than this CF of a situation. Want this park built? Wipe the slate clean and start over with a very expensive lesson learned.

Exactly!!!

http://kingwoodunderground.com/topic...d=11722526#END Soapboxmom [QUOTE] --- 7 days ago - quote - hide comments Don Allen Hobrook is coming back to milk the EMC cow again. He is working for Front Sight. We should never allow Holbrook to set foot in Texas again. Let's say no to Front Sight and Holbrook!!! Questions raised over economic developer’s new role | Pahrump Valley Times

joshuadrake --- 16 hours ago - quote - hide comments I agree with many here that insane people like soapboxmom, littleroundman, Prof. Henry Higgins eagle, and others from realscam are worst than any business practice. I will join the goal to have them and others persecuted or worse (hoping. To all zeek reward members who want to know why their program was closed it is these people with no life who cause issues. Most businesses pay their employees with new money and so does the government. So Zeek rewards members that were hurt go visit Soapboxmom and the insane group with bad lives in person.

u uic --- 16 hours ago - quote - hide comments Peddle your crap somewhere else. I am glad you and your cronies failed. No we do not beleive the junction of i 69 and roman forest is central to all America.

Holbrook has the most boneheaded scammers in town rushing to his defense. Now, a Zeekster has jumped in the fray:

SEC shuts down alleged $600 million Ponzi scheme - Aug. 17, 2012

Holbrook is going to be so sorry he opened this can of worms. His problems with Huber Heights have gone viral and he is attracting the lowest common denominator to be sure!

Soapboxmom

Earth Quest Adventures		Did You Know?		Economic Development		Scholarship Foundation
Earthquest Adventures Theme Park is a resort style thematic theme park currently under design to bring travel and tourism opportunities to the East Montgomery County area in the near future. LEARN MORE >>>

That page now goes to the Board minutes:

East Montgomery County Improvement District

So, we learn from the minutes that the new budget is approved and Earthquest Adventures is to receive NO funding. That is apparently the chicken's way out of saying it is not going forward. It is clearly dead, Jim!!!! That is the end of Holbrook's ridiculous blown up Dreamquest it appears.

Soapboxmom

Originally Posted by Soapboxmom

So, we learn from the minutes that the new budget is approved and Earthquest Adventures is to receive NO funding. That is apparently the chicken's way out of saying it is not going forward. It is clearly dead, Jim!!!! That is the end of Holbrook's ridiculous blown up Dreamquest it appears.

Soapboxmom

Any info who's going to get the blame for this ??

I'm busy all next week, so can you get Holbrooks' crack legal team to hold off until the following week to have me served ??

Just a Zeekster, SBM? That's like saying that refined sugar only comes in 1 pound bags and is solely used for making cakes.
In this case, the account joshuadrake has a link in his profile, that makes it appear that he is Joshua Kenneth Drake of Denver, Colorado (although his Google+ profile claims to be in Berkeley, California), a man who jumps on and promotes to death one bandwagon after another without caring what the truth behind them were before he starts.

Case in point... as "jkdrake1" in this discussion: http://jobitvideo.com/2012/05/26/leg...2-finance-act/

Looking around the Web, one finds his email account of 123jkd@gmail.com , phone number 352-359-3127, and Skype link of DrakeOne24 plastered across so many sites that one would think that he really should be worrying about The Streisand Effect being used against him if he throws his hat into the ring to lobby in favor of harming someone else. Like he seems to have here. Not just a Zeekster, he's also been pushing Royalty7, JustBeenPaid, UltraXProject, HugeYield, 10levelriches, Wealth4All, TextCashNetwork, and many others. Goodness gracious, the man offers to manage other people's money for them at the steep fee of 20% of their profits per month!

Originally Posted by littleroundman

Any info who's going to get the blame for this ??

I'm busy all next week, so can you get Holbrooks' crack legal team to hold off until the following week to have me served ??

I would be so honored to have you as a co-defendant, but Holbrook's attorney, Sue Seeberger, probably couldn't locate you regardless. The poor dear is still trying to find Pahrump, Nevada in Ohio. She did assure the judge that all of her third-party petition concerned Holbrook's dealings in Ohio mind you.

The delusional attorney wrote:

While Don Allen Holbrook, LLC may have other claims against the Third-Party
Defendants based on other Agreements breached in other jurisdictions outside of Ohio, Don
Allen Holbrook, LLC has not alleged those claims before this Court. All of the allegations in the
Counterclaim and the Third-Party Complaint arise from and relate to the breach of the
Agreement with the City.

Pahrump, Nevada is not in Ohio and has nothing to do with the folks in Huber Heights getting smart and sending that idiot Holbrook packing.

Don Allen Holbrook vs. Third-party Defendants Second Amended.pdf
Page 19: $80,000.00 in damages for Pahrump.

Memorandum in Opposition to Plaintiff's Motion to Strike Third-party Complaint.pdf

It appears Seeberger had a response due yesterday:

08/08/2012

ORDER SETTING SUBMISSION DATE MOTION TO DISMISS OF CYNTHIA CALVERT SUBMISSION ON 8/27/12; RESPONSE DUE 8/17/12; REPLY DUE 8/24/12

I am waiting for that with bated breath!

Soapboxmom

:

Attachment 1528

does place matter

ANYMORE?... YES, BUT!

By Don Holbrook, CEcD, FM....

The East Montgomery
County Improvement District (EMCID), as part of its
role in the Greater Houston Partnership, has responded
to market forces such as those identified in the Mega
Trends by looking at its market through the eyes of
investors, with no particular knowledge or affinity for
its region.

By following the five steps described next, EMCID not
only responded to recent economic setbacks such as the
loss of its own Astro-World Six Flags Theme Park but also capitalized on its strengths of being one of the
world’s leading energy centers. EMCID’s support for the
EarthQuest project has given it an entirely new approach
to recreating the brand of defining the greater Houston
economy for residents, employees, and visitors.

“We expect that EarthQuest will uniquely
fill a need in the US for green housing and
commercial space. When you consider it
alongside other, more high profile efforts
such as MASDAR in the UAE and Dong Tan
in China, EarthQuest will differ in that it
will be a practical, cost effective example of
how to utilize green technologies to
reduce carbon footprints and also be an
economically viable multi use master planned
diverse community. If we play our cards right,
it could become a standard for
responsible, practical development in this
new green economy as well as an
economic development engine for new
technology research and development.”

Dr. Matt Gardner, Chief Scientific Officer
The EarthQuest Institute, New Caney, Texas

Frank McCrady, president of EMCID, says “the
EarthQuest project evolved and has been successful
because we agreed early on that it would be necessary to
step outside the box of known realities and take calculat-
ed risks with private sector partners to define a new real-
ity that will deliver a future that will be full of new
opportunities for us and our region and recognized by
the private sector as a sound investment.”

In the case of EarthQuest, the EMCID board commis-
sioned a third party study by experts on this subject and
then sought additional expertise to review the findings of
the first conclusive report of findings and recommenda-
tions. This set the tone for further actions.....

EMCID created a consultant driven strategy for how
to fund the gaps in the financial conditions that would
need to be addressed to attract investor support to drive
a public-private partnership. This became the crux of its
foundation for incentives to close the deal, once terms
could be agreed upon that met economic development
goals and attracted an investor to support the capitaliza-
tion of the project.....

Again, EMCID and its new private investment partner
created an MOU of agreed upon deliverables, invest-
ments, and key milestones that would be supported by
expert advice on how to execute a planned project and
bring it to fruition....


In the end, the EarthQuest project created a new state
legislatively supported Economic Zone to enable the spe-
cial environment to exist in East Montgomery County to
allow the EarthQuest project to come to fruition.
EarthQuest built its investor package by leveraging
the relationships of the locale, region, and state and
required a comprehensive mesh of state, regional, and
local partnerships along with the private sector to create
economic development project that will meet the
market needs of the global investment culture.



“Communities need to be proactive in their
development of investment opportunities. With the
continued shrinkage of the planet through transportation and
communication technology, it is easier than ever to attract
consultants. These consultants say
simply “prove what you say” and sup-
port it with impartial third party
expert data and research, so my client
will feel comfortable making this
investment and then stand behind
your promises with the right cus-
tomized incentives that make our
business globally competitive.
Today, there is no room for cookie
cutter economic development poli-
cies.

Christopher G. Brown, P.E. President
Contour Entertainment, Inc.


In conjunction with a 1600-acre green master
planned community and a green-theme park which will
be the largest destination attraction in the country next to
Disney World, this project will have a huge economic
impact on the Houston region. It will play a key role in
key market forces such as site location consultants;
the process of transforming Houston into the renewable
energy capital of the world. The overall EarthQuest proj-
ect has both 501(c)(3) elements and a multi-billion dollar
private sector element that work in tandem to give
uniqueness to the overall EarthQuest project. The project
will have residential, retail, hospitality, entertainment,
commercial/office, research, education, and manufactur-
ing elements comprehensively balanced throughout the
1600-acre economic zone.

Economic Development Journal / Fall 2008 / Volume 7 / Number 4

This fantasy filled pile of excrement was published 4 years ago. Holbrook has been shoveling it high and deep for years. The IEDC sits back and cheers him on while he lies to and misleads clients and millions of tax dollars are wasted. The IDEC is a joke as it is clear they do not enforce their code of ethics and discipline their members. Who would trust anyone from that organization under these conditions?

EMCID has allowed Frank McCrady to run loose and wild and spend money virtually uncehecked. If Frank was in the real world working for a company, he would have been disciplined and fired long ago.

The taxpayers in EMC have been screwed out of literally millions of dollars by these carpetbaggers. Don Allen Holbrook also absconded with the charity money to the tune of at least $328,000.00 or more and left it defunct with not a single charitable purpose ever accomplished. Much of that money was tax dollars funneled through EMCID and the funds of hard working local business people who got burned by this pipe dream. Numerous local residents that bought into this con game made investments in hotels, RV parks and other businesses that have gone under while numerous breaking ground and completion dates have passed with nary a shovel full of dirt ever moved.

Holbrook is still parading around the country and desperately looking for more suckers to sell on his destination theme park garbage. Pahrump has been running him out and it is becoming more and more obvious why Huber Heights, Ohio filed suit. That whole contract centered on Holbrook furthering this same destination theme park scam that allows him and Contour to make hundreds of thousands of dollars even if the project is never funded and built.

In e-mails to Pahrump, Holbrook stated that Earthquest would break ground in December 2011 or early 2012. He also said that Contour had had control of the project as the developer since signing an agreement with EMCID in May 2011. That makes Contour yet another failed developer. After more than a year, they haven't even secured the funds to buy the property. Contour is now babbling about getting a new feasibility study. What part of EMCID doesn't have another dime to blow on this Fantasy Land is confusing for Contour???

http://www.pahrumpnv.org/images/uplo...14_Backup3.pdf

I am told that while wallowing in bankruptcy again, his Majesty, the Lord and master of the internet, is still living the lifestyle of the rich and famous. This *******, Don Allen Holbrook, had the nerve to waltz in and empty the coffers with the taxpayers taking 100% of the risk on this blown up Fantasy Land. Then, Holbrook had the absolute gall to turn around and sue the taxpayers and media that dared to speak out. I will work tirelessly to expose the truth and see no more good, honest taxpaying citizens get burned by Holbrook!!!

Soapboxmom

Flags Real Estate
Tracy Lee Supple
22616 Loop 494
Kingwood, TX 77339
281-682-6389 (Cell), 281-359-5881 (Office)
e-mail: Tracylee3888@tracyleerealty.com
Dinosaur Park – Earth Quest Adventure
Plan for dino park project grows
By ROYCELYN BASTIAN May 2, 2008
rbastian@hcnonline.com
Outlet malls, hotels and housing have been added to the EarthQuest Adventures Dinosaur Park project, according to the East Montgomery County Improvement District.
Initially, the project was proposed to just be a museum and theme park with a net ad valorem base of $700 million. After further discussion and additional planning, more activities have been added to the scope of the project.
“Since that time, we further discussed other components that will be contained in the development. Particularly a hotel site as well as other retail opportunities,” said Frank McCrady, president of EMCID. “With the investment group and developers that are looking at the project, they have gone far and above the initial concept of just a theme park.”
Along with the theme park and museum, developers are now looking into putting an eco-hotel component in the project that will offer treetop lodging. On the west side of the area will be the tourism attraction where there is room for four hotels in the development.
One of the biggest significant changes of the project is the ad valorem base of $700 million has increased to $1.5 billion, which includes hotel sites, outlet malls, outlet retail as well as low-, mid- and high-density housing.
“If you break apart the project, the majority of the housing development is contained for the Roman Forest community and the retail and outlet side is contained in the transportation corridor of U.S. Highway 59 on both sides,” McCrady said.
The theme park and museum will be on the further west part of the development. The project also includes space for future retail expansion and office space.
With changes to the dinosaur park, EMCID feels it has increased the investment in the community and diversified the base of the project instead of a single-purpose development.
The EMCID board of directors approved a memorandum of understanding on EarthQuest Adventures. This document outlines reimbursement procedures regarding the developer to reimburse EMCID for the amount of expenses that has been incurred on the front end of the project.
“Initially, we (EMCID) funded money in the beginning towards the project in the amount of $650,000 and our developer has agreed to reimburse us,” McCrady.
Beyond the $650,000 that the improvement district put in, it also committed to put in $4.5 million and is receiving consideration in the re-investment in the project.
“By the time we get to November, we are looking at doing a bond issue just to fund the developer $4,150,000,” he said.
The memorandum of understanding also covers the repayment by the for-profit once it receives its construction funding in 2009 and breaks ground. A portion of the construction fund will go back to EMCID.
If the project does not move forward, the agreement will allow EMCID to purchase certain tracts of land. The district started the project by committing to the museum, a 50-acre site.
“This is a binding document. Once we get to November, regardless of the economy, it puts the burden on EMCID to allocate the funding toward the developer for the reimbursement of their expenses,” McCrady said. “With economic development projects, there are inherent risks. A risk of $4 million in relation to a $1.5 billion investment in our community is a good return on your investment.”
For more information on EarthQuest Adventures, call the East Montgomery County Improvement District at 281-654-4419.
©Houston Community Newspapers Online 2008
__________________________________________________ __________________________________________________ _____
Dinosaur park gets green light
By ROYCELYN BASTIAN – March 4, 2008 rbastian@hcnonline.com
A memorandum of understanding regarding the future development of the dinosaur park and museum, also known as Earth Quest Adventures, should put the negative rumors flying around East Montgomery County to bed.
The East Montgomery County Improvement District along with the developers Marlin Atlantis and Don Lessum have ironed out the details regarding the 150-acre dinosaur park and 50-acre museum that is scheduled to be completed by 2012.
“The memorandum of understanding outlines the details of how the revenue for the dinosaur park is going to be utilized toward the development. We know the project investment is approaching close to $700 million and with that, we know that’s going to continue to grow,” said Frank McCrady, president of the East Montgomery County Improvement District.
Projections call for 2.5 million people to visit the dinosaur park in the first year, which will bring in a projected $175 million. Based on those numbers, EMCID is expected to catch a $1.75 million windfall from the amusement park project based on its 1 percent sales tax.
The agreement also finalized a zone sales tax, which will include an additional half-percent sales tax within the zone.
“From the zone, we anticipate that we should receive about $87,500 in revenue,” McCrady said. “There is also a proposed parking tax for cars, which are parked in the zone attending the venue and we are expecting 600,000 cars annually.”
With that, developers have pledged to contribute approximately $400,000 a year into the district’s scholarship endowment fund.
A hotel tax in the dinosaur park is another anticipated revenue stream for the area. Right now, there are 15 hotels that are scheduled to be built around the park, which will generate $1.8 million annually. The proposal also includes a 300-room hotel that will be constructed inside the park that is expected to generate $1.4 million in hotel tax annually.
“Another feature that we looked at is with travel and tourism projects coming to an under-served community. We think that our existing vendors should see a 14 percent increase in revenue and that will generate another $420,000 in annual sales tax,” McCrady said.
If things go according to plan, it is projected that approximately $6 million to $6.5 million will be utilized towards park improvements and other projects such as expansion in the water and theme park.
“Time wise, we should see them break ground in nine to 12 months on both the dinosaur park and museum,” McCrady said. “What you will see in the meantime is there will be a lot of engineering and environmental studies and testing done at the site.”
East Montgomery County was chosen as the site for Earth Quest Adventures out of approximately 64 communities around the country.
The improvement district as well as other members of the community worked closely with state representatives and senators to get a bill passed in the recent state Legislature. That effort was successful and the bill, HB 4015, is currently on the governor’s desk waiting to be signed.
It is projected that this 150-acre site will attract more than two and a half million people and will create 2,700 jobs in the area, with 30,000 jobs just for the construction phase. The economic revenue from this project will not only benefit EMC, it will also impact the another surrounding communities.
©Houston Community Newspapers Online 2008
__________________________________________________ __________________________________________________ ____
Dinosaur park promises mega fun
Wednesday, February 20, 2008
PATSY OLIVER
The expansive 150-acre dinosaur park, set to come to New Caney in mid-2010 if all goes as planned, promises to deliver fun for the entire family.
Since the demise of Astroworld has left some in the area hungry for a theme park, this new venture cannot come a moment too soon.
Andy Dill, president of the Community Chamber of Commerce of East Montgomery County, spoke to the Kingwood Realtor Advisory Board Feb. 14 about growth in East Montgomery County.
Dill said that although his portion of the county is often forgotten as part of Montgomery County as a whole, growth there is tremendous, and getting the dinosaur park is remarkable.
Dill explained that 68 cities and 29 states submitted proposals for the park, and New Caney was the developer's top pick. Dill explained that the man behind the park, Don Lessem, said that the East Montgomery County Improvement District's commitment to education was a deciding factor. Each year, EMCID awards $1,000 scholarships to all district residents who graduate from high school or earn GEDs, regardless of their age.
Lessem is a renowned paleontologist and consultant for the movie “Jurassic Park.” Dill said that education is of the utmost importance to Lessem, and that the new theme park will provide many opportunities for visitors, especially children, to interact and learn.
The destination has been named Earth Quest Adventures, leaving the concept open to many avenues for 'edutainment.' Dill said that visitors can expect a 4-D theater. He explained that “4-D is when everything around you is part of the deal. If a dinosaur sneezes, you're gonna get wet.”
He said that there will be a very chilly Arctic room, dinosaurs on display, and an observation station where visitors can interact with real paleontologists.
“The concept is that they would be talking live to paleontologists somewhere around the world on location at a dig site,” said Dill.
Earth Quest Adventures will be located off U.S. Highway 59 North, near FM 1485 and along Caney Creek. The first phase of the project, the $50-million museum, is set to break ground this year. An entirely green facility, the museum will have wind turbines on the roof and will generate its own electricity.
The total project is expected to include rides, a water park, a high-rise hotel and conference center, and more. It is anticipated to provide more than 2,700 jobs, plus thousands of construction jobs, and draw about 2.5 million visitors annually. The price tag has grown to 10 times the first-reported amount.
“Phase 1 is $50 million,” said Dill. “The project is now somewhere north of $500 million.”
© 2008 Ourtribune.com
Film adviser will design theme park in New Caney
Site to provide entertainment, research venue
By KATHERINE ECHOLS Chronicle Correspondent
8-1-2007
Plans are moving forward for "Dino" Don Lessem's Earth Quest Adventure Zone, a dinosaur-themed education and entertainment venture to open in New Caney by 2012.
Both the East Montgomery County Improvement District and Gov. Rick Perry are working hard to ensure that this project succeeds, officials said.
Perry recently signed House Bill 4015 to create a tax zone that will help finance the estimated $500-$600 million project. This tax will be included in the park's entry fee, said Frank McCrady, CEO of the East Montgomery County Improvement District.
Earth-friendly park
Lessem is a paleontologist, author and consultant who was an adviser for the Stephen Spielberg blockbuster Jurassic Park. His pet project has been called a dinosaur park, a dinosaur city and a theme park, but his concept for the park has remained relatively the same.
Don Holbrook, who is in charge of site selection and economic development for the New Caney area park, said Lessem envisions Earth Quest Adventure Zone as an earth-friendly park that will provide education through entertainment, create a renewed interest in dinosaurs and make Houston a premier dinosaur center.
This entertainment venue will not only educate park visitors about dinosaurs, but also about the relationship that human beings have with their planet, its animals and even technology, Holbrook said.
Hotel, theater planned
When Earth Quest Adventure Zone is completed, it will cover 250 acres north of Caney Creek and include dinosaur-themed exhibits, a hotel complex and spa and a theater complex tied to the hotel.
In addition, the park also will house a working research laboratory and the world's largest collection of dinosaurs and dinosaur bones. Holbrook said Earth Quest will be a center for dinosaur resources, research and education.
Further additions to the park are still being considered and may eventually include an immersive aquatic experience, animals, and an educational and entertaining online computer game that would allow participants to continue their gaming experience during their visit to Earth Quest.
Linking the park with a game would "put bricks and mortar to the online game experience," Holbrook said.
Not only does Earth Quest Adventure Zone represent Lessem's love of paleontology and his desire to share his passion through education, but it also represents his environmental conscience, Holbrook said.
The park will be engineered so that it can use alternative energy systems.
"As a green park or green zone, it will demonstrate how we can live in harmony with the environment and, whenever possible, offset (our) ties to fossil fuels," Holbrook said. "People really respect (Don) because he does what he says he'll do."

Mega Fantasy Land blow up and Don Allen Holbrook had a finger in every single pie. He worked for the failed developer, EMCID, the defunct charity, brought in friends for the fundraising and other consulting. He and his LLC made at least 1.2 million from 2007-2010. Why has our Montgomery County not taken more decisive action??? Don doesn't do what he says he will do. He just laughs all the way to the bank!!!

Soapboxmom

kuhf houston public radio
public radio news & information twenty four hours a day from houston, tx


KUHF Business News
Tuesday AM April 14th, 2009

by: Ed Mayberry

Plans are still underway for an Epcot-styled green theme park, as part of a "green" community here in Houston. Ed Mayberry talked with economic development consultant Don Holbrook for an update.

The new EarthQuest development will encompass retail stores, an outlet mall, restaurants and hotels, a convention center, office space, a research facility, a zoo — and "green" homes, according to Don Holbrook, president and CEO of the EarthQuest Institute.


"We're excited about it. I mean, it's — we've been in the process of planning this for six years, so we think the kind of a perfect storm came along and helped us. But we're going to break ground probably next year — first or second quarter of 2010 — with opening planned in 2012, late 2012. My original undergraduate degree was in urban planning and environmental studies. So I joke that I've been a 'green' developer for all my career, which I won't say how many years that is, but it's getting up there now, at this point."

EarthQuest Institute is a non-profit entity advocating green technologies. The institute is overseeing a planned museum and various education components in conjunction with the “green” vision of this master-planned community, according to Holbrook, who attended a recent forum on alternative energy.

"We're excited by it. We're hoping that President Obama will get the credit markets opened up! We're not worried about the equity, we're worried about the debt markets! But very excited, we think Houston's a great place for this. It's the energy center of the country. There's no one pixie dust solution for all this. It's a collaboration of all the energy companies and technologies that we believe are going to create the solutions. And so we're excited to be kind of that showcase, to show those off for people here in Houston — to make Houston not only just a huge eco-tourism and green tourism destination in the country, but a great place to come and learn about sustainable energy, clean technologies, energy conservation and see things from around the world."
The EarthQuest Resort will be located off of highway 59 in New Caney.

Ed Mayberry, KUHF Houston Public Radio News.

The Kingwood Underground rocks!

u uic --- 22 min ago - quote - hide comments A true investment is not talked about its built. So EMCID gave money to a man that just talked. Why are they not filing a lawsuit themselves? Are they part of the scheme? A simple blog does not shut down a project. These questions were asked many years ago when taxes skyrocketed. At the end of the day show what your worth. There is nothing to show except a bankruptcy and empty promises. No investor would spend money on this project. All SBM did was one person that stopped the madness of lies. Mr Holbrook should be happy he got money for nothing. All he did was preach a scheme and he risked nothing.

Holbrook's bankruptcy is getting very juicy:

Holbrook Bankruptcy Objection.pdf

Holbrook Bankruptcy Objection 2.pdf

Holbrook Monthly Operating Report July.pdf

Holbrook Bankruptcy Lawyer Compensation.pdf

Those expenses just don't make any sense. I am glad the bank from KY has objected. They should get to foreclose on that rental property that makes Holbrook $500.00 a month. He is out living like a king while trying to reduce all those payments and write off mountains of debt again. The lawyer is sure making a killing off of Holbrook's shenanigans! How many others in bankruptcy have a secret business account to draw off of as they wish??? No way he is living the way that paperwork makes it look that he is.

Soapboxmom

What a scam. This outfit is the Town of Pahrump Lawyers. I wonder if he is getting a discount for them filing.

LOUIS M. BUBALA III, ESQ.
Nevada State Bar No. 8974
ARMSTRONG TEASDALE LLP
50 W. Liberty St., Ste. 950
Reno, NV 89501
Telephone: 775.322.7400
Facsimile: 775.322.9049
Email: lbubala@armstrongteasdale.com
GORDON R. GOOLSBY, ESQ.
Nevada State Bar No. 11578
ARMSTRONG TEASDALE LLP
3770 Howard Hughes Pkwy., Ste. 200
Las Vegas, NV 89169
Telephone: (702) 678-5070
Facsimile: (702) 878-9995
Email: ggoolsby@armstrongteasdale.com

ATTENTION!!!!!GROUNDBREAKING NEWS!!!!!....Dirt finally being moved on EarthQuest project!!!!!....will update on my next post

After recording unusually high seismic readings from the New Caney/Roman Forest area, a U. S. Geological Survey team was sent to investigate. Upon further investigation, it was determined a massive colony of termites finished devouring the stumps and root systems of the trees that had surrounded the faded EarthQuest sign, and are furiously tunneling thier way to the wooden poles holding it up!!!!

Originally Posted by fjjm303

What a scam. This outfit is the Town of Pahrump Lawyers. I wonder if he is getting a discount for them filing.

LOUIS M. BUBALA III, ESQ.
Nevada State Bar No. 8974
ARMSTRONG TEASDALE LLP
50 W. Liberty St., Ste. 950
Reno, NV 89501
Telephone: 775.322.7400
Facsimile: 775.322.9049
Email: lbubala@armstrongteasdale.com
GORDON R. GOOLSBY, ESQ.
Nevada State Bar No. 11578
ARMSTRONG TEASDALE LLP
3770 Howard Hughes Pkwy., Ste. 200
Las Vegas, NV 89169
Telephone: (702) 678-5070
Facsimile: (702) 878-9995
Email: ggoolsby@armstrongteasdale.com

They want to foreclose on Don Holbrook's Kentucky home he uses as a rental property. Kudos to them for objecting to his attempts to rework the loan when he is living the lifestyle of the rich and famous while in bankruptcy. Thumbs down for the nonsense going on in Pahrump! Of course getting involved in Holbrook's bankruptcy might enlighten them.

Originally Posted by pantherdadX2

After recording unusually high seismic readings from the New Caney/Roman Forest area, a U. S. Geological Survey team was sent to investigate. Upon further investigation, it was determined a massive colony of termites finished devouring the stumps and root systems of the trees that had surrounded the faded EarthQuest sign, and are furiously tunneling thier way to the wooden poles holding it up!!!!

Nah, can't be true.

Even termites wouldn't swallow that B/S.

Holbrook's attorney is still chasing around poor Craig Malisow after all this time.

GREGORY A. BRUSH
MONTGOMERY COUNTY CLERK OF COURTS
41 N. PERRY STREET, DAYTON, OHIO 45222
INSTRUCTIONS FOR SERVICE
CITY OF HUBER HEIGHTS OHIO
PLAINTIFF/PETITIONER
2012 CV 02947
DON ALLEN HOLBROOK LLC
DEFENDANT/RESPONDENT
PLEASE ISSUE SERVICE TO: (Name and Address)
CRAIG MALISOW
CO THE HOUSTON PRESS
1621 MILAM STREET SUITE 100
HOUSTON, TX 77002
VIA: Regular Mail
SERVICE PROVIDER:
TO BE SERVED (List all Documents to be Served)
AMENDED COMPLAINT SECOND AMENDED THIRD-PARTY COMPLAINT WITH EXHIBITS
ATTACHED FILED BY SUE SEEBERGER
Electronically Requested by: Sue Seeberger
Attorney for: DON ALLEN HOLBROOK LLC
ELECTRONICALLY FILED
COURT OF COMMON PLEAS
Friday, August 17, 2012 3:22:31 PM
CASE NUMBER: 2012 CV 02947 Docket ID: 17445494
GREGORY A BRUSH
CLERK OF COURTS MONTGOMERY COUNTY OHIO

This is such a loser of a case. Malisow published nothing until April. Him asking for info for an article to be published in April had nothing to do with the fact Huber Heights was unsatisfied with Holbrook's work in March and possibly before. I hope the many defendants turn this around on that creep Holbrook! I certainly did not loan Malisow nor the officials in Huber Heights my time travel broomstick!

Soapboxmom

1
IN THE COMMON PLEAS COURT OF MONTGOMERY COUNTY, OHIO
CIVIL DIVISION
CITY OF HUBER HEIGHTS, OHIO
Plaintiff,
v.
DON ALLEN HOLBROOK, LLC
Defendant/Third-Party Plaintiff
v.
Heather Dobrott, et al.,
Third-Party Defendants.
CASE NO. 2012-CV-02947
JUDGE MICHAEL TUCKER
MEMORANDUM IN OPPOSITION OF
DEFENDANT/THIRD-PARTY
PLAINTIFF DON ALLEN
HOLBROOK, LLC TO THIRD-PARTY
DEFENDANTS CYNTHIA CALVERT’S
AND HARTBURG PUBLICATIONS,
LLC’S MOTION TO DISMISS FOR
LACK OF PERSONAL JURISDICTION
AND MOTION TO QUASH SERVICE
OF PROCESS
I. INTRODUCTION
Defendant/Third-Party Plaintiff Don Allen Holbrook, LLC (“Defendant” or “DAH,
LLC”) opposes Third-Party Defendants Cynthia Calvert’s and Hartburg Publications, LLC’s
Motion to Dismiss for Lack of Personal Jurisdiction and Motion to Quash Service of Process
(“Motion to Dismiss”) to dismiss the Second Amended Third-Party Complaint (“Third-Party
Complaint”) filed against them under the holding in Kauffman Racing Equip., LLC v. Roberts,
126 Ohio St.3d 81, 2010-Ohio-255, ¶ 74, in which the Ohio Supreme Court refused “to allow a
non-resident defendant to take advantage of the conveniences that modern technology affords
and simultaneously be shielded from the consequences of his intentionally tortious conduct.” Id.
Thus, DAH, LLC asks this Court to deny the Motion to Dismiss and to quash service of process
ELECTRONICALLY FILED
COURT OF COMMON PLEAS
Friday, August 17, 2012 3:14:59 PM
CASE NUMBER: 2012 CV 02947 Docket ID: 17445430
GREGORY A BRUSH
CLERK OF COURTS MONTGOMERY COUNTY OHIO2
and to conclude that this Court has personal jurisdiction over Third-Party Defendants Cynthia
Calvert and Hartburg Publications, LLC (“HP, LLC”) under R.C. 2307.382(A)(3) and (6) and
that they have been properly served with process under Civ.R. 4.3(A)(3) and (9) and to conclude
that exercising personal jurisdiction over them will not violate the Due Process clause of the
United States Constitution.
II. STATEMENT OF FACTS
DAH, LLC is an Arizona limited liability company registered to conduct business in the
State of Ohio and also conducts business around the United States of America and elsewhere as
an economic developer in the public and private sectors. Third-Party Complaint, ¶ 1. Mrs.
Calvert lives in Kingwood, Texas. Affidavit of Cynthia Calvert (“Calvert Aff.”), ¶ 1. Mrs.
Calvert is a member and Chief Executive Officer of HP, LLC, dba The Tribune. Calvert Aff., ¶
2. The website for The Tribune is Ourtribune.com. Calvert Aff., ¶ 12.
Mrs. Calvert and HP, LLC have attached an article she wrote and posted on February 7,
2012 as part of Exhibit A to her Affidavit, in which she makes questionable and unsupported
factual statements about possible criminal and/or unethical conduct by DAH, LLC as an
economic developer. Calvert Aff. ¶ 8 and Exhibit A attached thereto. Mrs. Calvert has
published articles including defamatory, derogatory, and false statements about Don Allen
Holbrook, LLC, that she later posted on ourtribune.com and has not stopped other from reposting her defamatory, derogatory, and false statements and articles, in order that such postings
exploit search engine optimization on websites such as Google so that defamatory, derogatory,
and false statements about Don Allen Holbrook, LLC, go “viral” and are listed at the beginning
of a search for “Don Allen Holbrook, LLC”, “Don Holbrook”, “Holbrook” or other variations on
the name, on internet search engines and which postings which have been seen and downloaded 3
from the internet by persons residing in the State of Ohio, including but not limited to,
Court gives EarthQuest developer time to raise money, save project - Tuesday, February 07, 2012 - Copyright 2007 Ourtribune.com - Wednesday, December 31, 1969 - Copyright 2007 Ourtribune.com
=13408; and http://www.ourtribune. com/article.php?id=13452. Third-Party Complaint, ¶ 7.
Internet postings and articles by Mrs. Calvert on Ourtribune.com have been seen
and downloaded by persons in Ohio, including but not limited to Shelli Nestle, Steven Carne,
and Roger Reynolds. See Affidavit of Shelli Nestle (“Nestle Aff.”), ¶¶ 1-2 attached hereto as
Exhibit A; Affidavit of Roger Reynolds (“Reynolds Aff.”), ¶¶ 1-2 attached hereto as Exhibit B;
Affidavit of Steven Carne (“Carne Aff.”), ¶¶ 1-2 and attached hereto as Exhibit C. All of these
negative threads and postings began well before February 28, 2012. Nestle Aff., ¶ 3; Reynolds
Aff., ¶ 3; and Carne Aff., ¶ 3.
DAH, LLC entered an Agreement with the City of Huber Heights, Ohio (“City”) to
perform an economic development business case analysis with the assistance of the City Staff
and collaboration of the current developer. Affidavit of Don Allen Holbrook (“Holbrook Aff.”),
¶ 2 and attached hereto as Exhibit D; Third-Party Complaint, ¶¶ 14-20 and Exhibit 1 attached
thereto. The City Council adopted a Resolution on December 12, 2011, approving the
Agreement and payments to DAH, LLC. Third-Party Complaint, ¶¶ 14-16 and Exhibit 2
attached thereto. Under the Agreement, the City was to be invoiced a total of $66,000.00, of
which the City has only paid $53,800.00 leaving an outstanding balance of $12,200.00 owed,
thereby breaching the Agreement. Counterclaim, ¶ 39.
The Agreement stated that the recommended “scope of work . . . . would require the
assistance of the City Staff and collaboration of the current developer to provide information and
collaborate on conceptual development strategies.” See Exhibit 1 attached to the Third-Party
Complaint. Donnie Jones, Assistant City Manager, was directed by former City Manager Gary 4
Adams to work with DAH, LLC on various incentives and financing models, but failed to do so.
Third-Party Complaint, ¶¶ 22, 24, 25, 30, 31, 33.
On Tuesday, February 7, 2012, Mrs. Calvert admits that she posted an article entitled
“Court gives EarthQuest developer time to raise money, save project” on Ourtribune.com,
which included the following purportedly factual statements about Don Allen Holbrook as an
economic developer:
“But the road that Holbrook has traveled, both to New Caney, Texas, and
numerous other towns across the U.S.A., is a long and winding journey,
littered with disappointment and controversy.
Furthermore, a diligent search by The Tribune of documents, newspaper articles,
public filings, websites, etc., paints a vastly different portrait of this supposed
‘entrepreneur extraordinaire”. And it seems that trouble follows Holbrook to
almost every town that invites him into their community, and their coffers.
For example, . . .
. . . . Another disturbing fact is that The Tribune has not been able to get
answers as to how much Holbrook or [Don] Lessem were paid by EMCID for his
EarthQuest-related efforts. A brief analysis of EMCID payments in 2008 and
2009 reveal thousands of dollars spent on airfare, hotels and meals for Holbrook
to travel to New Caney as well as for EMCID staff and board members to travel
to Nevada to see Holbrook. Notwithstanding, The Tribune has learned from
similar contracts made available by other cities in which Holbrook and/or
Contour [Entertainment] are involved, that their contracts are not simple
documents for a single stated amount. In fact, quite the opposite is true.
But Holbrook’s difficulties and inconsistencies don’t end with his work. . . .
Holbrook’s employment history over the years is also troubling. He was hired
and subsequently fired in several locations, mired in controversy. In 1996,
Holbrook [was] hired by the Port Authority in Red Wing, Minnesota, and
terminated in 1998 for questionable spending practices, falsifying his resume, etc.
In 2001, he was hired by the Lake Havasu partnership for Economic Development
but less than two years later, his employment contract [was] not renewed. In
2004, Holbrook was hired by the Richmond, Indiana Economic Development
Corporation but 16 months later, left in an acrimonious departure after excessive
spending, unauthorized expenditures and other questionable practices came to
light in the local paper. . . .”
Calvert Aff. ¶ 8 and Exhibit A attached thereto (emphasis added). Mrs. Calvert’s purported 5
factual statements are not true but are false and defamatory and impugn the professional and
ethical reputation of DAH, LLC and accuse Don Holbrook of criminal conduct and have caused
harm to DAH, LLC in the State of Ohio and elsewhere. Holbrook Aff. ¶ 11 (a) to (c). These
purportedly factual statements were published on the internet well before the March 14, 2012
meeting at which the City breached the Agreement. Holbrook Aff. ¶ 8.
In an email dated February 29, 2012 to DAH, LLC, Mr. Adams said that he had been
contacted by a reporter in a city near Houston, Texas, asking if the City had a contract with
DAH, LLC, which Mr. Adams confirmed, and then Mr. Adams told DAH, LLC in an email that
it was a “strange conversation”, but that he was not concerned about it because it did not pertain
to the City. Third-Party Complaint, ¶¶ 12, 26-28; Holbrook Aff., ¶ 3.
At a meeting on March 14, 2012 between DAH, LLC and members of the City Staff,
including Mayor Ron Fisher and Mark Campbell, a member of the City Council, Mr. Campbell
said, without any warning to DAH, LLC, that the City no longer wanted a relationship with
DAH, LLC, did not believe that the City had received any value for the monies paid, and
demanded a full refund of all monies paid under the Agreement. Third-Party Complaint, ¶ 34;
Holbrook Aff., ¶ 5.
Mr. Carne attended an earlier meeting on March 14, 2012, as a member of the Executive
Board of the Montgomery County Agricultural Society and is also associated with DAH, LLC.
Carne Aff., ¶ 4; Holbrook Aff., ¶ 4. Mr. Carne spoke to Mayor Fisher on March 15, 2012, and
Mayor Fisher told Mr. Carne that Jim Borland, Acting City Manager (after Mr. Adams), gave
Mr. Campbell copies of internet research on DAH, LLC and that Mr. Campbell gave copies to
Mayor Fisher. Carne Aff., ¶ 6.
After the meeting on March 14, 2012 when Mr. Campbell demanded a full refund of all 6
monies paid to DAH, LLC, DAH, LLC learned that Heather Dobrott, aka “soapboxmom” on
www.realscam.com and Cynthia Calvert on Ourtribune.com, had been posting comments
and articles that are untrue, defamatory, and negative. Holbrook Aff., ¶ 9. Mrs. Dobrott, Mrs.
Calvert, Mr. Maurizio, and possibly others have been posting and re-posting each other’s
defamatory, untrue, derogatory, and false statements about DAH, LLC on various websites on
the internet, including but not limited to realscam.com, pvtimes.com, houstonpress.com,
ourtribune.com, to exploit search engine optimization algorithms to intentionally cause harm to
Don Allen Holbrook, LLC in Ohio and elsewhere. Holbrook Aff., ¶ 12. Mr. Holbrook has seen
on various websites that Mrs. Dobrott was repeatedly posting and linking to articles by Mrs.
Calvert and refers to Mrs. Calvert as “our Cynthia”. Holbrook Aff., ¶ 13. On April 8, 2012,
Mayor Fisher told Mr. Carne that he wanted to drop the lawsuit against DAH, LLC and walk
away. Carne Aff., ¶ 7. On April 10, 2012, Mr. Carne told Mr. Holbrook about his conversations
with Mayor Fisher, including the statements about internet research. Carne Aff., ¶ 8. Holbrook
Aff., ¶ 14.
III. UNDER OHIO LAW, OHIO COURTS ARE OPEN TO ALL PERSONS.
As a preliminary matter, this Court must reject the implicit argument running throughout
Mrs. Calvert’s and HP, LLC’s Motion to Dismiss that because DAH, LLC is not an Ohio limited
liability company, it cannot seek redress for an injury it suffered in Ohio in an Ohio court. Mrs.
Calvert’s and HP, LLC’s argument is contrary to Ohio law. The Ohio Supreme Court has
explained that the “courts of this state are, and always will be, as open to a non-resident plaintiff
as to citizens of this state, provided they meet the necessary statutory requirements imposed by
the General Assembly.” Howard v. Allen, 30 Ohio St.2d 130, 137 (1972).
Article I, Section 16 of the Ohio Constitution, the “Open Courts” amendment, is entitled 7
“Redress in courts” and states in part:
“All courts shall be open, and every person, for an injury done him in his
lands, goods, person, or reputation, shall have remedy by due course of law, and
shall have justice administered without denial or delay. . . .”
Emphasis added. Thus, under the Ohio Constitution, Ohio courts are open to “every person”, not
just residents of the state. R.C. 1.59(C) states that “‘[p]erson’ includes an individual,
corporation, business trust, estate, trust, partnership, and association.” As the Ohio Supreme
Court explained above in Howard, a non-resident plaintiff may sue in Ohio courts provided it
meets the necessary statutory requirements, which in this case is R.C. 2307.382, the Ohio longarm statute. Notably, R.C. 2307.382 does not include the word “resident” anywhere to restrict
who may bring a claim for affirmative relief against a non-resident defendant.
IV. UNDER OHIO LAW, THIS COURT HAS PERSONAL JURISDICTION OVER
MRS. CALVERT AND HP, LLC.
When a defendant asserts a lack of personal jurisdiction as a defense to a complaint, the
burden is on the plaintiff to establish that the trial court has personal jurisdiction over the
defendant. Enquip Technologies Group, Inc. v. Tycon Technoglass, S.r.l., Greene App. No.
2010-CA-23, 2010-Ohio-6100, at ¶ 10 (2
nd
Dist.), citing Jurko v. Jobs Europe Agency, 43 Ohio
App.3d 79, 85 (8
th
Dist. 1975). A plaintiff is required to make only a prima facie showing of
personal jurisdiction to withstand a motion to dismiss. Kauffman Racing Equip., LLC v.
Roberts, 126 Ohio St.3d 81, 2010-Ohio-255, at ¶ 27, citing Fallang v. Hickey, 40 Ohio St.3d
106, 107 (1988). Allegations in pleadings are accepted because under Ohio law, “an admission
in a pleading dispenses with proof and is equivalent to proof of the fact.” J. Miller Express, Inc.
v. Pentz, 107 Ohio App.3d 44, 48 (9
th
Dist. 1995), citing Rhoden v. Akron, 61 Ohio App.3d 725,
727 (9
th
Dist. 1988) (“. . . an admission made in pleadings dispenses with the need to prove the
truth of the matter admitted.”). Affidavits, depositions, interrogatories, or other oral testimony 8
may be used because matters relating to personal jurisdiction may not be apparent on the face of
the summons or complaint. Jurko at 85. In considering whether a plaintiff has made its prima
facie showing, a court must (1) view the allegations in the pleadings and any documentary
evidence in a light most favorable to the plaintiff; and (2) resolve all reasonable competing
inferences in favor of the plaintiff. Goldstein v. Christiansen, 70 Ohio St.3d 232, 236 (1994).
In order for an Ohio trial court to exercise personal jurisdiction over a non-resident
defendant, it uses a two-step analysis to determine: (1) whether R.C. 2307.382(A) and Civ.R.
4.3(A) confer personal jurisdiction; and, if so, (2) whether the exercise of personal jurisdiction
would deprive a non-resident defendant of the right to due process of law under the Fourteenth
Amendment to the United States Constitution. Enquip Technologies Group at ¶ 10, citing
Kauffman Racing Equip. at ¶ 28. Ohio courts use this analysis because R.C. 2307.382 and
Civ.R. 4.3(A) do not confer personal jurisdiction to the limits of the Due Process clause.
Goldstein at 238 n.1. This two-step analysis applies to cases involving the use of the internet and
websites. Kauffman Racing Equip. at ¶ 25. Also, this Court may take limited judicial notice of
website addresses and whether a website is interactive or for informational purposes only. See
Malone v. Berry, 174 Ohio App.3d 122, 2007-Ohio-6501, at ¶ 13 (10
th
Dist.). Thus, DAH, LLC
has the burden to make a prima facie showing to this Court that it has personal jurisdiction over
Mrs. Calvert and HP, LLC.
A. A plaintiff makes a prima facie showing of personal jurisdiction by alleging
conduct to meet the requirements under R.C. 2307.382(A).
In order for an Ohio court to exercise personal jurisdiction over an out-of-state defendant,
a plaintiff must allege that an out-of-state defendant, directly or by an agent, engaged in specific
enumerated activities identified in R.C. 2307.382(A), including the following sections relevant to
DAH, LLC’s claims for civil conspiracy, tortious interference with contract and prospective 9
business relations, and defamation against Mrs. Calvert and HP, LLC:
(A) A court may exercise personal jurisdiction over a person who acts directly or
by an agent, as to a cause of action arising from the person’s:
(3) causing tortious injury by an act or omission in this state; . . . .
(6) causing tortious injury in this state to any person by an act outside
this state committed with the purpose of injuring persons, when he
might reasonably have expected that some person would be injured
thereby in this state; . . . .
Emphasis added. To assert a tortious injury under R.C. 2307.382(A)(3) and Civ.R. 4.3(A)(3), a
plaintiff need only make a prima facie showing that it suffered a tortious injury in the state of
Ohio by an act or an omission by the defendant. In Kauffman Racing Equip., the Ohio Supreme
Court concluded that the tort of defamation had been committed in Ohio by a non-resident
defendant who posted allegedly defamatory statements on the Internet when the plaintiff showed
evidence that Ohioans had seen these statements on the Internet, thus meeting the material
element of publication of the comments in Ohio. Id. at ¶¶ 41-42, citing Keeton v. Hustler
Magazine, Inc., 465 U.S. 770, 777 (1984); Fallang v. Hickey, 40 Ohio St.3d 106, 107 (1988).
The Ohio Supreme Court in Kauffman Racing Equip. also concluded that “even if” the
defendant had not published his internet postings within the state of Ohio, the defendant was “not
shielded from the reach of Ohio’s long arm” statute. Kauffman Racing Equip. at ¶ 43. The
Court concluded that R.C. 2307.382(A)(6) and Civ.R. 4.3(A)(9) allow an Ohio court to exercise
personal jurisdiction over a non-resident defendant and provide for effective service of process
“if the cause of action arises from a tortious act committed outside Ohio with the purpose of
injuring persons, when the nonresident defendant might reasonably have expected that some
person would be injured thereby in Ohio.” Kauffman Racing Equip. at ¶ 43, citing Clark v.
Connor, 82 Ohio St.3d 309, 313 (1998). 10
In Kauffman Racing Equip., the Ohio Supreme Court found that although the defendant’s
publication of his tortious comments did not emanate from Ohio, that the plaintiff made a prima
facie showing that the tortious comments were published in Ohio, meaning that the tort was
committed in Ohio. Id., citing Keeton v. Hustler Magazine, Inc., 465 U.S. 770, 777 (1984);
Fallang at 107. The Ohio Supreme Court reasoned: “Roberts posted his allegedly defamatory
statements on the Internet, ostensibly for the entire world to see.” Kauffman Racing Equip. at ¶
42. Because the plaintiff produced evidence that Ohioans saw the defendant’s postings, the Ohio
Supreme Court found that the defendant’s statements were published in Ohio, the alleged tort
was committed in Ohio and that R.C. 2307.382(A)(3) and Civ.R. 4.3(A)(3) were applicable. Id.
Alternatively, the Ohio Supreme Court concluded in Kauffman Racing Equip. that the
requirements under R.C. 2307.382(A)(6) and Civ.R. 4.3(A)(9) were met when defamatory
statements made outside Ohio had the purpose of injuring persons in Ohio, then there is a
reasonable expectation that the purposefully inflicted injury will occur in Ohio. Id. at ¶ 44.
B. If a Court finds personal jurisdiction under R.C. 2307.382(A), it must next
determine whether its exercise of personal jurisdiction will comport with an
out-of-state defendant’s Due Process rights.
Even if this Court concludes that DAH, LLC has made a prima facie showing under R.C.
2307.382(A) and Civ.R. 4.3(A), then Ohio law requires a court to consider whether exercising
personal jurisdiction will violate an out-of-state defendant’s rights to due process of law.
Goldstein at 235. The due process clause under the Fourteenth Amendment limits the power of
state courts to enter judgments against a nonresident. Kulko v. California Superior Court, 436
U.S. 84, 91 (1978). The Due Process clause permits a court to obtain either general or specific
jurisdiction over a non-resident defendant depending on the nature of the defendant’s contacts
with the forum state. Kauffman Racing Equip. at ¶ 46. DAH, LLC has not alleged that Mrs. 11
Calvert’s and HP, LLC’s contacts with Ohio have been of a “continuous and systematic nature”
for this Court to exercise general jurisdiction. DAH, LLC has alleged that its cause of action is
related to or arises out of Mrs. Calvert’s and HP, LLC’s contacts with Ohio for this Court to
exercise specific jurisdiction. Id. at ¶ 47, citing Helicopteros Nacionales de Colombia v. Hall,
466 U.S. 408, 414 (1984).
Specific jurisdiction is permitted if the defendant’s contacts with Ohio meet the factors
identified in the three-part test established in Southern Machine Co. v. Mohasco Indus., Inc., 401
F.2d 374, 381 (6
th
Cir. 1968). First, a defendant must purposefully avail herself of the privilege
of acting in the state or causing a consequence in the state. Second, the causes of action must
arise from the defendant’s activities. Third, the defendant’s actions or the consequences of
defendant’s action must have a substantial enough connection with the state to make a court’s
exercise of jurisdiction over the defendant reasonable. Southern Machine at 381.
When the first two factors are met under the Southern Machine analysis, an inference
arises that the third “reasonableness” factor is also present. Kauffman Racing Equip. at ¶ 71.
Among the factors relevant to the reasonableness inquiry are that a state has a significant interest
in redressing injuries that actually occur within the state and “that a high degree of unfairness is
required to erect a constitutional barrier against jurisdiction.” Kauffman Racing Equip. at ¶ 72
(citations omitted).

V. THIS COURT SHOULD CONCLUDE THAT DAH, LLC HAS MADE A PRIMA
FACIE SHOWING THAT THIS COURT HAS PERSONAL JURISDICTION
OVER MRS. CALVERT AND HP, LLC.
Under Ohio law, nonresident defendants cannot use the Internet as a shield to protect
them from the consequences of otherwise intentionally tortious conduct. Acting in concert with
others to tortiously interfere with another’s contracts or business relations and publishing 12
statements intended to injure another’s business reputation, exposing another to public ridicule,
shame and/or disgrace for the purpose of adversely affecting another in its trade, business, or
profession are intentional torts whether such acts are committed with older technology, such as
writing letters, or such acts are committed with new technology such as the Internet. This Court
must view all allegations in the pleadings and the documentary evidence in a light most
favorable to DAH, LLC and must resolve all competing inferences in its favor. Kauffman
Racing Equip. at ¶ 27. This Court should conclude that DAH, LLC has made a prima facie
showing in its Third-Party Complaint that this Court should exercise personal jurisdiction over
Mrs. Calvert and HP, LLC and deny their Motion to Dismiss and Motion to Quash Service.
A. DAH, LLC has met its burden to make a prima facie showing of personal
jurisdiction under R.C. 2307.382(A).
DAH, LLC has made a prima facie showing under R.C. 2307.382(A)(3) that Mrs. Calvert
and HP, LLC have caused tortious injury to DAH, LLC by an act in Ohio and/or under R.C.
2307.382(A)(6) that Mrs. Calvert and HP, LLC have caused tortious injury in Ohio to DAH,
LLC by an act outside of Ohio committed with the purpose of injuring DAH, LLC, when Mrs.
Calvert and HP, LLC might reasonably have expected that DAH, LLC would be injured thereby
in Ohio. In fact, Mrs. Calvert and HP, LLC have admitted that an article was posted on
Ourtribune.com, on February 7, 2012 making numerous unfounded factual statements
about alleged criminal activity and/or alleged unethical conduct by DAH, LLC concerning other
economic development projects in Pahrump, Nevada, Montgomery County, Texas, “and
numerous other towns across the U.S.A.” See Calvert Aff., ¶ 8, and Exhibit A attached thereto.
DAH, LLC has made a prima facie showing that Mrs. Calvert and HP, LLC have published
statements that are defamatory per se and/or per quod and have published those statements
“ostensibly for the entire world to see.” Kauffman Racing Equip. at ¶ 42. In addition to the 13
evidence in Mrs. Calvert’s own Affidavit, DAH, LLC, has presented 3 Affidavits that Ohioans
have seen and downloaded voluminous false and derogatory comments from various websites,
including HP, LLC’s website, which began well before February 28, 2012. Thus, under the
holding in Kauffman Racing Equip., Mrs. Calvert’s and HP, LLC’s comments and links posted
on the Internet were published in Ohio. Id.
Moreover, this Court should resolve any reasonable competing inferences in its favor by
concluding that it is reasonable that the “internet research” given to Mr. Campbell and to Mayor
Fisher were printed pages from Third-Party Defendants, including Mrs. Calvert’s and HP, LLC’s
defamatory and unfounded purportedly factual statements about DAH, LLC’s involvement with
development projects in Nevada, Texas, and unnamed locations elsewhere in the U.S.A.
Furthermore, DAH, LLC has alleged, and Mrs. Calvert and HP, LLC have not denied, that they
worked in concert with other Third-Party Defendants by posting links to each other’s websites
and comments, that the Third-Party Defendants were engaged in a civil conspiracy, and as a
proximate result of the civil conspiracy to defame DAH, LLC, tortiously interfered with the
Agreement by procuring its breach.
Under R.C. 2307.382(A)(3), DAH, LLC has made a prima facie showing that it was
injured in Ohio based on the statement that Mayor Fisher made to Mr. Carne on March 15, 2012,
the day after the City breached the Agreement, that “internet research” had been given to Mr.
Campbell and to him. Carne Aff., ¶ 6. Alternatively, under R.C. 2307.382(A)(6), DAH, LLC
has made a prima facie showing that it was injured by an act outside Ohio committed with the
purpose of injuring DAH, LLC, when Mrs. Calvert and HP, LLC might reasonably have
expected that DAH, LLC would be injured thereby in Ohio. This Court should conclude that
DAH, LLC has met its burden to make a prima facie showing under R.C. 2307.382(A)(3) and (6) 14
that this Court has personal jurisdiction over Mrs. Calvert and HP, LLC.
B. DAH, LLC has met its burden to make a prima facie showing that exercising
personal jurisdiction over Mrs. Calvert and HP, LLC will not violate their
due process rights.
DAH, LLC has asserted that this Court has specific jurisdiction over Mrs. Calvert and
HP, LLC by alleging that its causes of action arise out of or are related to their contacts with
Ohio. Under the three-part test from Southern Machine Co., DAH, LLC has shown first, that
Mrs. Calvert and HP, LLC purposefully availed themselves of the privilege of acting in Ohio or
causing a consequence in Ohio by regularly and frequently posting defamatory comments on her
website and posting links to others’ websites with defamatory comments about the professional
reputation and conduct of DAH, LLC. Second, DAH, LLC has shown that the causes of action
arise from Mrs. Calvert’s and HP, LLC’s activities on the Internet which have been seen in Ohio.
Third, Mrs. Calvert’s and HP, LLC’s acts or the consequences caused by their acts have a
substantial enough connection with Ohio to make the exercise of personal jurisdiction
reasonable. Southern Machine Co. v. Mohasco Industries, Inc., 401 F.2d 374, 381 (6
th
Cir.
1968). If the first two factors of this test are satisfied, then a reasonable inference arises that the
third factor is also present. Kauffman Racing Equip. at ¶ 71 (citations omitted).
DAH, LLC has met its burden to show that Mrs. Calvert and HP, LLC have purposefully
availed themselves of the privilege of acting in Ohio or causing consequences in Ohio by posting
a series of articles with purportedly factual statements impugning DAH, LLC’s professional and
ethical conduct and comments on the Internet intended to harm the business reputation of and to
adversely affect DAH, LLC in its trade, its business, or profession. Mrs. Calvert’s and HP,
LLC’s articles and others’ defamatory comments about DAH, LLC, specifically exploit search
engine optimization algorithms on search engine websites so that the negative comments appear 15
at the beginning of search results for “Don Allen Holbrook, LLC”, “Don Allen Holbrook”, “Don
Holbrook”, or “Holbrook”, constituting cyber-bullying, cyber-stalking, and cyber-harassment,
for the whole world to see on the Internet.
In Kauffman Racing Equip., the Ohio Supreme Court followed the analysis in Calder v.
Jones, 465 U.S. 783 (1984) and rejected the analysis in Reynolds v. Internatl. Amateur Athletic
Fedn., 23 F.3d 1110 (6
th
Cir. 1994), neither of which involved Internet communications of
defamatory material. Kauffman Racing Equip. at ¶ 61. Notably, the Court in Kauffman Racing
Equip. rephrased the conclusion in Calder to the following question relevant to the facts before
it: “should a company injured in Ohio need to go to Virginia to seek redress from a person who,
though remaining in Virginia, knowingly caused injury in Ohio?” Id. at ¶ 56. Then, examining
cases involving defamatory material on the Internet, the Court looked at Cadle Co. v.
Schlictmann, 123 Fed. Appx. 675 (6
th
Cir. 2005) (no personal jurisdiction because alleged
defamatory statements on defendant’s passive website were not related to plaintiff’s activities in
Ohio) and Oasis Corp. v. Judd, 132 F. Supp. 2d 612 (S.D. Ohio 2001) (no personal jurisdiction
because no evidence that defendants’ communications were received by anyone in Ohio other
than plaintiff). Id. at ¶¶ 63-63.
Given the voluminous nature of these comments in concert with others on
Ourtribune.com and on other interactive websites which have been seen by others in Ohio,
Mrs. Calvert’s and HP, LLC’s contacts are not “random”, “fortuitous”, or “attenuated”, but
instead show that they have created a substantial connection with Ohio rising to purposeful
availment, particularly by reason of her article dated February 7, 2012, by which they should
have reasonably anticipated being haled into court in Ohio, where DAH, LLC was also acting
under an Agreement with the City of Huber Heights as an economic developer. This Court 16
should resolve competing inferences in favor of DAH, LLC and conclude that Mrs. Calvert and
HP, LLC knew about the Agreement with the City at least by February 7, 2012 based on Mrs.
Calvert’s express reference to Holbrook working in other “numerous other towns across the
U.S.A.”, or by February 29, 2012, when Mr. Adams reported receiving a telephone call from a
reporter.
The Court in Kauffman Racing Equip. concluded that the “effects analysis” in Calder
requires conduct “‘calculated to cause injury’ in a ‘focal point’ where the ‘brunt’ of the injury is
experienced.” Kauffman Racing Equip. at ¶ 66 (citation omitted). The content of Mrs. Calvert’s
and HP, LLC’s voluminous postings show that they intended to harm the professional reputation
of DAH, LLC and which proximately resulted in harm to DAH, LLC in Ohio as seen in the
statements:
“But the road that Holbrook has traveled, both to New Caney, Texas, and
numerous other towns across the U.S.A., is a long and winding journey,
littered with disappointment and controversy.
Furthermore, a diligent search by The Tribune of documents, newspaper articles,
public filings, websites, etc., paints a vastly different portrait of this supposed
‘entrepreneur extraordinaire”. And it seems that trouble follows Holbrook to
almost every town that invites him into their community, and their coffers.
For example, . . .
. . . . The Tribune has learned from similar contracts made available by
other cities in which Holbrook and/or Contour [Entertainment] are involved,
that their contracts are not simple documents for a single stated amount. In
fact, quite the opposite is true.
But Holbrook’s difficulties and inconsistencies don’t end with his work. . . .
Holbrook’s employment history over the years is also troubling. He was hired
and subsequently fired in several locations, mired in controversy. . . .”
Calvert Aff. ¶ 8 and Exhibit A attached thereto. Mrs. Calvert’s statements purport to relate facts,
not opinions, and show an intentional bias against Mr. Holbrook and DAH, LLC. Mr. Holbrook
attests that Mrs. Calvert’s purported factual statement about “numerous other towns” is not true 17
and that Mrs. Calvert fails to give any specifics. Holbrook Aff., ¶ 11a. Mrs. Calvert’s purported
factual statement that “trouble follows Holbrook to almost every town that invites him into their
community, and their coffers” is not true and that Mrs. Calvert fails to give any specifics.
Holbrook Aff., ¶ 11b. Finally, Mr. Holbrook specifically rebuts Mrs. Calvert’s purported factual
statements regarding his employment history in Red Wing, Minnesota, Lake Havasu, Nevada,
and Richmond, Indiana as untrue. Holbrook Aff., ¶ 11c. This Court should conclude that DAH,
LLC has made a prima facie showing that Mrs. Calvert and HP, LLC have purposefully availed
themselves of Ohio law.
Second, Mrs. Calvert’s and HP, LLC’s contacts with Ohio are related to the operative
facts alleged in the Third-Party Complaint so that the causes of action have a substantial
connection with Mrs. Calvert’s and HP, LLC’s activities in Ohio. Id. at ¶ 70. By maintaining a
website and not stopping others from re-posting her articles and comments, Mrs. Calvert and HP,
LLC are exploiting search engine optimization algorithms, so that any time the names “Don
Allen Holbrook, LLC”, “Don Allen Holbrook”, “Don Holbrook” or “Holbrook” are searched on
Internet search websites, negative and defamatory articles and comments are listed at the top of
any search results. Mrs. Calvert and HP, LLC have thus maintained contacts with Ohio.
Finally, this Court should infer because the first two factors are present, the third factor is
also met. Specifically, while there are a number of factors to consider under the reasonable
inquiry centering on a plaintiff’s residency in the forum, they are not the only factors to consider.
Id. at ¶ 72. Singular among the reasons that the claims against Mrs. Calvert and HP, LLC should
be tried in Ohio is the fact that the City has sued DAH, LLC here. Notably, a state has a
significant interest in redressing injuries that occur within the state. Id. Moreover, the Court in
Kauffman Racing Equip. noted that a high degree of unfairness is required to erect a 18
constitutional barrier against jurisdiction. For these reasons, this Court should conclude that
DAH, LLC has met the three factors under the Southern Machine analysis and that the exercise
of personal jurisdiction over Mrs. Calvert and HP, LLC will not deprive them of their due
process rights.
VI. CONCLUSION
In sum, this Court should view the evidence in a light most favorable to DAH, LLC,
should conclude that DAH, LLC has made a prima facie showing of personal jurisdiction over
Mrs. Calvert and HP, LLC under the long-arm statute, that the exercise of personal jurisdiction
will not deprive them of their rights of due process, and deny their Motion to Dismiss and to
quash service of process.
Respectfully Submitted,
s/Sue Seeberger
Sue Seeberger (0059730)
5975 Kentshire Drive, Suite D
Dayton, Ohio 45440-4264
Voice: (937) 291-8646
Fax: (937) 291-8650
sueseeberger@biegeltye.com
Attorney for Defendant/Third-Party Plaintiff
Don Allen Holbrook, LLC19
CERTIFICATE OF SERVICE
I certify that a copy of the foregoing was served by the Court’s e-filing system or by ordinary
mail on this 17
th
day of August, 2012, upon the following:
L. Michael Bly (mbly@pselaw.com)
Joshua M. Kin (jkin@pselaw.com)
Pickerel, Schaeffer & Ebeling Co.
2700 Kettering Tower
Dayton, Ohio 45423
Attorneys for Plaintiff
Robert P. Bartlett, Jr. (rbartlett@ficlaw.com)
Andrew J. Reitz (areitz@ficlaw.com)
Faruki Ireland & Cox PLL
500 Courthouse Plaza, SW
10 North Ludlow Street
Dayton, Ohio 45402
Attorneys for Third-Party Defendants Stephens
Media, LLC dba Pahrump Valley Times; and The
Houston Press, The Houston Press dba Village
Voice Media Holdings, LLC dba Houston Press,
LP dba Backpage.com, LLC and Craig Malisow
Adam R. Webber
Falke & Dunphy, LLC
30 Wyoming Street
Dayton, Ohio 45409
Attorney for Heather Dobrott and Cynthia Calvert,
The Tribune, aka, Ourtribune.com
Frank Maurizio
581 China Street
Pahrump, Nevada 89048-0782
s/Sue Seeberger

Holbrook's attorney is doing a briliant job of arguing in favor of Cynthia Calvert, Frank Maurizio and I getting our Motions to Dismiss granted.

Mrs. Calvert’s and HP,
LLC’s articles and others’ defamatory comments about DAH, LLC, specifically exploit search
engine optimization algorithms on search engine websites so that the negative comments appear 15
at the beginning of search results for “Don Allen Holbrook, LLC”, “Don Allen Holbrook”, “Don
Holbrook”, or “Holbrook”, constituting cyber-bullying, cyber-stalking, and cyber-harassment,
for the whole world to see on the Internet.

http://ssl.csg.org/dockets/2012cycle...ing%20Laws.pdf
Holbrook's nut of an attorney is accusing the defendants of criminal activity. I will be raising absolute hell over these ridiculous and very damaging accusations! It will be viral!!!

Notably, the Court in Kauffman Racing
Equip. rephrased the conclusion in Calder to the following question relevant to the facts before
it: “should a company injured in Ohio need to go to Virginia to seek redress from a person who,
though remaining in Virginia, knowingly caused injury in Ohio?”

The defendants could not possibly have knowingly caused injury in Ohio. We were blogging about Pahrump and Texas and issues related to those matters of public concern. Nobody said a word about Ohio until that lunkhead Holbrook got his rear sued there. Nothing was directed to or concerning Ohio until April 29th after the suit against him was already filed by Huber Heights. Can't Holbrook and this lady read??? Thanks, for arguing in favor of our dismissal motions, Seeberger!

Mrs. Calvert’s and HP, LLC’s contacts are not “random”, “fortuitous”, or “attenuated”, but
instead show that they have created a substantial connection with Ohio rising to purposeful
availment, particularly by reason of her article dated February 7, 2012, by which they should
have reasonably anticipated being haled into court in Ohio, where DAH, LLC was also acting
under an Agreement with the City of Huber Heights as an economic developer. This Court 16
should resolve competing inferences in favor of DAH, LLC

We could not possibly have conceived of being hauled into Ohio court for posting truthfully about other matters of public concern. Ditto my previous answer!

Mr. Holbrook specifically rebuts Mrs. Calvert’s purported factual
statements regarding his employment history in Red Wing, Minnesota, Lake Havasu, Nevada,
and Richmond, Indiana as untrue.

Boy, why not draw lots more attention to your previous little debacles!!! Does Donny want to argue with the official Red Wing Board minutes?

Red Wing:
http://www.realscam.com/f11/don-alle...html#post20999
http://www.realscam.com/f11/don-alle...html#post21000
http://www.realscam.com/f11/don-alle...240/#post19576
http://www.realscam.com/f11/don-alle...html#post21016
http://www.realscam.com/f11/don-alle...html#post23267

Richmond, Indiana:
Talk of the Town: EDC SAYS GOODBYE TO HOLBROOK (using the false Phd. designation as the liar has done for years)
http://www.realscam.com/f11/don-alle...html#post20906
http://www.realscam.com/f11/don-alle...html#post20684
http://www.realscam.com/f11/don-alle...html#post21602

Lake Havasu:
http://www.realscam.com/f11/don-alle...html#post23261 (Holbrook doesn't even have his dates of employment there correct)
http://www.realscam.com/f11/don-alle...html#post21014
http://www.realscam.com/f11/don-alle...html#post21108
http://www.realscam.com/f11/don-alle...html#post20745
http://www.realscam.com/f11/don-alle...html#post19612
http://www.realscam.com/f11/don-alle...html#post21317
http://www.realscam.com/f11/don-alle...html#post23257

By maintaining a
website and not stopping others from re-posting her articles and comments, Mrs. Calvert and HP,
LLC are exploiting search engine optimization algorithms, so that any time the names “Don
Allen Holbrook, LLC”, “Don Allen Holbrook”, “Don Holbrook” or “Holbrook” are searched on
Internet search websites, negative and defamatory articles and comments are listed at the top of
any search results.

That is one of the most ignorant and lame-brained postulations ever made. Stop people from re-posting and commenting on things that are public on the internet??? If anyone copies me rest assured I will hunt you down and give you 50 lashes with a wet noodle after I thank you for sharing the truth and helping to warn and inform the public of course!

Soapboxmom

Ohio civil conspiracy law is quite fascinating:

https://docs.google.com/viewer?a=v&q...z-sW78nEe-m3-Q

the elements of civil conspiracy

in Ohio are: (1) a malicious combination, (2) two or more persons,

(3) injury to person or property, and (4) existence of an unlawful

act independent from the actual conspiracy. Conspiracy cannot be

made the subject of a civil action unless something is done which,

in the absence of the conspiracy allegation, would give rise to a cause of action.

The unlawful act itself must be accomplished or

completed before an action in civil conspiracy will lie. [Internal

citations omitted.] Seminatore v. Dukes, Cuyahoga App. No. 84032,

http://www.weldinginfonetwork.com/li...MSJGranted.pdf

In Ohio, civil conspiracy requires plaintiffs to show the existence of “a malicious
combination of two or more persons to injure another in person or property in a way not
competent for one alone, resulting in actual damages.” Williams v. Aetna Fin. Co.
(1998), 83 Ohio St.3d 464, 475. Because conspiracy is not a free-standing tort, plaintiffs
must also establish the existence of a separate, independent wrong. Wilson v. Harvey
(Ohio App. 8 Dist), 2005-Ohio-5722, at 41. And that independent wrong must have been
not a negligent act, but an intentional one. Hicks v. Bryan Med. Grp., Inc. (N.D. Ohio
2003), 287 F. Supp.2d 795, 813.

Civil Liability for Conspiracy - Conspiracy

In order to amount to a civil conspiracy, the parties to the conspiracy have to be aware of the wrongful nature of the act and the harm it may cause at the time of agreement to commit an act[iv]. The intention to achieve an unlawful object is an element in civil conspiracy.

If no direct act is done in furtherance of the conspiracy, there is no civil liability[v]. A person can bring an action only if some damage have been caused to him/her due to the overt acts of the conspirators[vi].
A person who was present at the time of commission of an offense need not be liable for the harm caused if it can be proved that there was no agreement from his/her part[vii].

http://www.niu.edu/law/organizations...ns%2037-68.pdf

The court explained, “By its nature, tort liability arising from conspiracy
presupposes that the coconspirator is legally capable of committing the tort,
i.e., that he or she owes a duty to plaintiff recognized by law and is potentially
subject to liability for breach of that duty.”29 The court added, “Conspiracy
is not an independent tort; it cannot create a duty or abrogate an
immunity. It allows tort recovery only against a party who already owes
the duty and is not immune from liability based on applicable substantive
tort law principles.”.....

Permitting
a plaintiff to maintain a conspiracy claim against a defendant that does
not owe him or her a duty magnifies the potential for abuse.....

Specifically, the court rejected plaintiffs’ “guilt by
association” theory as exceeding the boundaries of a duty of care.177 The
court also identified the “burdening of fundamental rights of [free] speech
and association,” and the punitive and chilling affect allowing liability
would have

The civil conspiracy allegation will be blowing up in Holbrook's face. Frank Maurizio and I only became acquainted because of Don Allen Holbrook threatening to sue us both. That happened long after Huber Heights had sent the buffoon packing and demanded a refund. I suppose Sue Seeberger is going to insist we conspired via the use of my time travel broomstick.

Then there is that conspiracy to write totally factual, well researched articles and posts that we all engaged in. I asked for advice on how to get the Earthquest Institute records that according to the IRS and Texas Non-profit corporation act must be available. Don A. Holbrook is the president and CEO and the one hiding those records. Why don't we discuss the conspiracy between all those involved including Frank McCrady who are concealing said records against the letter of the law. Dr. Matthew Gardner did send those to the EMCID office, so we all know exactly where those documents are housed. No doubt the Ohio judge will open that Pandora's box.

A conspiracy to perpetuate the truth by all the journalists and bloggers. Diabolical!!!!

Soapboxmom

For those in need of some comic relief, please scroll to the end of the filing made by Holbrook's attorney that is linked below. Holbrook's Affidavit is quite something. I linked many of the posts about his departures from various jobs in a post above. Check out those meeting minutes and juxtapose them with the under oath testimony of Holbrook in his Affidavit.

Holbrook's Response to Calvert Motion to Dismiss.pdf

New Caney ISD approves $3.5M sports complex land deal. What a surprise. Holbrook is not mentioned anywhere in the article from our tribune.