Crawford v. City of Dallas et al
| Cassandra Bryant Crawford |
| City of Dallas, Emily Worland, Mark Adams, Perry Kilgo and Texas Receivership Group LLC |
| 3:2025cv01758 |
| July 7, 2025 |
| U.S. District Court for the Northern District of Texas |
| Karen Gren Scholer |
| Renee Harris Toliver |
| Contract: Negotiable Instrument |
| 28 U.S.C. § 1343 Violation of Civil Rights |
| Plaintiff |
Docket Report
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| Filing 78 OBJECTION filed by Cassandra Bryant Crawford re: #76 Findings and Recommendations on Motion re: #58 Motion for Leave to File, filed by Cassandra Bryant Crawford, #43 Motion to Dismiss/Lack of Jurisdiction, filed by Texas Receivership Group LLC, Mark Adams, Perry Kilgo. (Crawford, Cassandra) |
Filing 77
ELECTRONIC ORDER: In light of the recommendation of the Findings, Conclusions and Recommendation of the United States Magistrate Judge, filed December 22, 2025, that all of Plaintiff's claims be dismissed without prejudice, see Doc. #76 , Plaintiff's pending pretrial motions, Docs. #4 , #7 , #12 , #16 , #19 , #21 , #22 , #23 , #24 , #26 , #27 , #30 , #32 , #51 , #58 , #67 , and #75 are TERMINATED AS MOOT. In the event the district judge declines to accept the recommendation of the magistrate judge, Plaintiff may re-urge her motions. (Ordered by Magistrate Judge Rene Harris Toliver on 12/23/2025) (Magistrate Judge Rene Harris Toliver)
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Filing 76
FINDINGS, CONCLUSIONS AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE: For the foregoing reasons, Defendants Mark Adams, Perry Kilgo, and Texas Receivership Group LLC's Motion to Dismiss for Lack of Jurisdiction, Doc. #43 , and Defendant City of Dallas and Emily Worland's Motion to Dismiss for Lack of Jurisdiction and for Failure to State a Claim, Doc. #52 , should be GRANTED. Plaintiff's claims against Defendants should be DISMISSED WITHOUT PREJUDICE for lack of subject matter jurisdiction. And as no claims will remain, the Clerk of the Court should be directed to close this case. (Ordered by Magistrate Judge Rene Harris Toliver on 12/22/2025) (kcr) Modified judge association on 12/23/2025 (kcr).
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| Filing 75 MOTION for Hearing TO PROCEED ON FEDERAL CLAIMS AND NOTICE OF STATE COURT FINALITY filed by Cassandra Bryant Crawford (Crawford, Cassandra) |
| Filing 74 REPLY filed by Cassandra Bryant Crawford re: #71 Response/Objection (Crawford, Cassandra) |
| Filing 73 NOTICE of State Court Mandate and Absence of Any Ongoing State Proceedings filed by Cassandra Bryant Crawford (Attachments: #1 Exhibit(s) EXHIBIT A MANDATE) (Crawford, Cassandra) Modified text on 12/11/2025 (knb). |
| Filing 72 RESPONSE AND OBJECTION filed by Cassandra Bryant Crawford re: #43 MOTION to Dismiss for Lack of Jurisdiction (Attachments: #1 Affidavit(s) EXHIBIT A1) (Crawford, Cassandra) |
| Filing 71 RESPONSE filed by Mark Adams, Perry Kilgo, Texas Receivership Group LLC re: #67 MOTION to Compel Limited Disclosure (Espinosa, Eduardo) |
| Filing 70 RESPONSE filed by Cassandra Bryant Crawford re #52 MOTION to Dismiss for Lack of Jurisdiction and for Failure to State a Claim, #53 Brief/Memorandum in Support of Motion PLAINTIFF CONSOLIDATED RESPONSE, SUPPLIMENTAL BRIEF, AND AFFIRMATIVE DEFENSES TO DEFENDANTS CITY OF DALLAS'S MOTION TO DISMISS (Attachments: #1 Exhibit(s) EXHIBIT LIST, #2 Exhibit(s) EXHIBIT A ONC APPLICATION, #3 Exhibit(s) EXHIBIT B 18 ROOM LODGING HOUSE, #4 Exhibit(s) EXHIBIT C BOA RULING/COMPLIANCE PLAN, #5 Exhibit(s) EXHIBIT D WORLAND EMAIL, #6 Exhibit(s) EXHIBIT E PI, #7 Exhibit(s) EXHIBIT F ORDER APPT RECEIVER, #8 Exhibit(s) EXHIBIT G BOA APPEAL HEARING) (Crawford, Cassandra) Modified event text on 12/9/2025 (kcr). |
| Filing 69 REPLY filed by Cassandra Bryant Crawford re: #68 Response/Objection (Attachments: #1 Exhibit(s) June 16,2025 Email from Asst. City Attorney Emily Worland to the Court, #2 Exhibit(s) Order Denying Plaintiff''s June 26, 2025 Motion (Court of Appeals, #3 Exhibit(s) Order Denying Motion for Reconsideration and Motion to Waive Supersedeas (Court of Appeals), #4 Exhibit(s) July 2, 2025 Order Taking No Action on Pending Motions (Court of Appeals)) (Crawford, Cassandra) |
| Filing 68 RESPONSE filed by Mark Adams, Perry Kilgo, Texas Receivership Group LLC re: #58 MOTION for Leave to File Second Amended Complaint(With Newly Discovered Evidence and Updated Damages) (Napoli, Michael) |
| Filing 67 MOTION to Compel Limited Disclosure filed by Cassandra Bryant Crawford (Crawford, Cassandra) |
| Filing 66 NOTICE of Supplemental Evidence filed by Cassandra Bryant Crawford (Attachments: #1 Exhibit(s) Exhibit A - Supplemental Evidence: Filing by Co-Defendant Isiah Payne (Motion to Stay)) (Crawford, Cassandra) |
| Filing 65 NOTICE of EMERGENCY SUPPLEMENTAL NOTICE (Addressing Receivers missrepresentation of TRO's and Statutory Authority (ECF #59 filed by Cassandra Bryant Crawford (Attachments: #1 Exhibit(s) EXHIBIT A tRANSCRIPT BOA Exherpts) (Crawford, Cassandra) |
| Filing 64 REPLY filed by City of Dallas re: #52 MOTION to Dismiss for Lack of Jurisdiction and for Failure to State a Claim (Spaniol, Andrew) |
| Filing 63 NOTICE of Filing EHXIBIT B filed by Cassandra Bryant Crawford (Attachments: #1 Exhibit(s) EXHIBIT B Cancellation Email) (Crawford, Cassandra) |
| Filing 62 RESPONSE filed by Cassandra Bryant Crawford re: #59 Response/Objection (Crawford, Cassandra) |
| Filing 61 NOTICE of Plaintiff's Short Supplemental Notice of Procedural Due Process Issues and New Evidence filed by Cassandra Bryant Crawford (Attachments: #1 Exhibit(s) EXHIBIT A (Motion To Clarify Controling Orders Filed in DC-23-08770) (Crawford, Cassandra) |
| Filing 60 Appendix in Support filed by Mark Adams, Perry Kilgo, Texas Receivership Group LLC re #59 Response/Objection (Napoli, Michael) |
| Filing 59 OBJECTION filed by Mark Adams, Perry Kilgo, Texas Receivership Group LLC re: #51 MOTION for Protective Order (Napoli, Michael) |
| Filing 58 MOTION for Leave to File Second Amended Complaint(With Newly Discovered Evidence and Updated Damages) filed by Cassandra Bryant Crawford (Attachments: #1 Exhibit(s) Second Amended Complaint) (Crawford, Cassandra) Modified text on 12/8/2025 (kxm). |
| Filing 57 Supplemental NOTICE pf Filing Exhibit C re: #56 Notice (Other) filed by Cassandra Bryant Crawford (Attachments: #1 Exhibit(s) Transcript excerpt confirming Acknowledgement of Granted Certificate of Occupacy and Assurance of Continued Ownership) (Crawford, Cassandra) Modified text on 11/10/2025 (knb). |
| Filing 56 NOTICE of Ongoing Ultra Vires Conduct filed by Cassandra Bryant Crawford (Attachments: #1 Exhibit(s) Notice of Unlawful interference with Private Sale and Unfunded Receiver Lien, #2 Exhibit(s) Receiver Motion to Force Sale Homestead Property) (Crawford, Cassandra) Modified text on 11/10/2025 (knb). |
| Filing 55 RESPONSE AND OBJECTION filed by Cassandra Bryant Crawford re: #52 MOTION to Dismiss for Lack of Jurisdiction and for Failure to State a Claim (Attachments: #1 Cover Sheet Supplement Notice Of Filngng Supplemental Exhibit in Opposition to Motion to Dismiss, #2 Exhibit(s) Exhibit A Supplimental Filing In Support of Pending Emergency Motions And Request for Protective Relief) (Crawford, Cassandra) |
| Filing 54 Appendix in Support filed by City of Dallas re #53 Brief/Memorandum in Support of Motion to Dismiss for Lack of Jurisdiction and Failure to State a Claim (Spaniol, Andrew) |
| Filing 53 Brief/Memorandum in Support filed by City of Dallas re #52 MOTION to Dismiss for Lack of Jurisdiction and for Failure to State a Claim (Spaniol, Andrew) |
| Filing 52 MOTION to Dismiss for Lack of Jurisdiction and for Failure to State a Claim filed by City of Dallas (Spaniol, Andrew) |
| Filing 51 MOTION for Protective Order filed by Cassandra Bryant Crawford (Attachments: #1 Exhibit(s) Sworn Declaration) (Crawford, Cassandra) |
| Filing 50 OBJECTION filed by Mark Adams, Perry Kilgo, Texas Receivership Group LLC re: #48 Response/Objection, (Napoli, Michael) |
| Filing 49 REPLY filed by Mark Adams, Perry Kilgo, Texas Receivership Group LLC re: #43 MOTION to Dismiss for Lack of Jurisdiction (Napoli, Michael) |
| Filing 48 RESPONSE filed by Cassandra Bryant Crawford re: #43 MOTION to Dismiss for Lack of Jurisdiction (Attachments: #1 Exhibit(s) Exhibits In Support of Declaration of Plaintiffs Response and Objection to Defendants Motion to Dsmiss) (Crawford, Cassandra) |
| Filing 47 RESPONSE filed by Cassandra Bryant Crawford re: #43 MOTION to Dismiss for Lack of Jurisdiction (Attachments: #1 Exhibit(s) Exhibits A -G, #2 Proposed Order Proposed Order Denial Defendants Motion for Dismissal) (Crawford, Cassandra) |
| Filing 46 Proposed Order to #43 Motion to Dismiss/Lack of Jurisdiction, by Defendants Mark Adams, Perry Kilgo, Texas Receivership Group LLC. (Napoli, Michael) Modified text on 10/20/2025 (kaf). |
| Filing 45 Appendix in Support filed by Mark Adams, Perry Kilgo, Texas Receivership Group LLC re #44 Brief/Memorandum in Support of Motion to Dismiss (Napoli, Michael) |
| Filing 44 Brief/Memorandum in Support filed by Mark Adams, Perry Kilgo, Texas Receivership Group LLC re #43 MOTION to Dismiss for Lack of Jurisdiction (Napoli, Michael) |
| Filing 43 MOTION to Dismiss for Lack of Jurisdiction filed by Mark Adams, Perry Kilgo, Texas Receivership Group LLC. Party Texas Receivership Group LLC added.Attorney Michael D Napoli added to party Mark Adams(pty:dft), Attorney Michael D Napoli added to party Perry Kilgo(pty:dft), Attorney Michael D Napoli added to party Texas Receivership Group LLC(pty:dft) (Napoli, Michael) |
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Filing 42
IT IS ORDERED that Defendant City of Dallas's Unopposed Motion to Extend Time to File Responsive Pleading, Doc. #41 , is GRANTED. The City of Dallas's response to Plaintiff's amended complaint is due on November 4, 2025. (Ordered by Magistrate Judge Rene Harris Toliver on 10/14/2025) (chmb)
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| Filing 41 Unopposed MOTION to Extend Time to file responsive pleading filed by City of Dallas Attorney Andrew G Spaniol added to party City of Dallas(pty:dft) (Spaniol, Andrew) |
| Filing 40 SUMMONS Returned Executed as to Perry Kilgo; served on 9/26/2025. (knb) |
| Filing 39 SUMMONS Returned Executed as to Mark Adams; served on 9/23/2025. (knb) |
| Filing 38 SUMMONS Returned Executed as to City of Dallas; served on 9/23/2025. (knb) |
| Filing 37 SUMMONS Returned Executed as to Emily Worland; served on 9/23/2025. (knb) |
| Filing 36 SUMMONS Returned Executed as to Other Unknown Agents. (knb) |
| Filing 35 CERTIFICATE OF SERVICE by Cassandra Bryant Crawford re #34 Amended Complaint. (kcr) (Main Document 35 replaced with corrected image on 9/24/2025) (kcr). |
| Filing 34 FIRST AMENDED COMPLAINT FOR INJUCTIVE RELIEF, DAMAGES, AND CONSTITUTIONAL VIOLATIONS against Mark Adams, City of Dallas, Perry Kilgo, Emily Worland filed by Cassandra Bryant Crawford. Unless exempted, attorneys who are not admitted to practice in the Northern District of Texas must seek admission promptly. Forms, instructions, and exemption information may be found at www.txnd.uscourts.gov, or by clicking here: # Attorney Information - Bar Membership. If admission requirements are not satisfied within 21 days, the clerk will notify the presiding judge. (kcr) |
| Filing 33 Summons Issued as to Mark Adams, City of Dallas, Perry Kilgo, Other Unknown Agents, Isiah T Payne, Emily Worland. (kcr) |
| Filing 32 MOTION for Hearing and for Temporary Stay/Injunction re #31 Notice Supplemental Evidence filed by Cassandra Bryant Crawford with Brief/Memorandum in Support. (Crawford, Cassandra) |
| Filing 31 NOTICE of Supplemental Evidence Packet filed by Cassandra Bryant Crawford (Attachments: #1 Exhibit(s) Supplemental Evidence, #2 Exhibit(s) Supplememtal, #3 Exhibit(s) Supplemental, #4 Exhibit(s) Supplemental) (Crawford, Cassandra) |
| Filing 30 Emergency MOTION for Temporary Restraining Order filed by Cassandra Bryant Crawford (Attachments: #1 Proposed Order Granting Emergency Motion for Temporary Restraining Order) (Crawford, Cassandra) |
| Filing 29 NOTICE of Change in Circumstances filed by Cassandra Bryant Crawford (Crawford, Cassandra) |
| Filing 28 Brief/Memorandum in Support filed by Cassandra Bryant Crawford re #27 Emergency MOTION for Temporary Restraining Order and Temporary Injunction (Attachments: #1 Proposed Order granting Emergency TRO) (Crawford, Cassandra) Modified text on 8/15/2025 (knb). |
| Filing 27 Third Emergency MOTION for Temporary Restraining Order and Temporary Injunction filed by Cassandra Bryant Crawford (Crawford, Cassandra) Modified text on 8/15/2025 (knb). |
| Filing 26 MOTION to Strike Fraudulent Deed of Trust filed by Cassandra Bryant Crawford. (Attachments: #1 Declaration(s) Notice of Retalitory Risk, #2 Proposed Order to Motion to Strike Receiver Deed of Trust, #3 Additional Page(s) Manual Certificate of Service) (Crawford, Cassandra) Modified text on 8/6/2025 (knb). |
| Filing 25 CERTIFICATE OF SERVICE by Cassandra Bryant Crawford re #19 Emergency MOTION to Compel, #21 Emergency MOTION to Authorize Sale of Homestead Property and Enjoin City Interference, #22 Supplemental and Amended Emergency MOTION to Authorize Sale of Homestead Property and Enjoin City Interference, #24 Supplemental Emergency Motion - Eminent Harm and Interference with Sale (Crawford, Cassandra) Modified event text and linkage on 8/6/2025 (knb). |
| Filing 24 MOTION Supplemental Emergency Motion - Eminent Harm and Interference with Sale filed by Cassandra Bryant Crawford. ***FILED USING EMERGENCY FILING EMAIL*** (Attachments: #1 Additional Page(s)) (cea) |
| Filing 23 Emergency MOTION to Authorize Immediate Sale of Homestead Property and to Enjoin City and Receiver from Interfering or Delaying filed by Cassandra Bryant Crawford with Brief/Memorandum in Support. (Attachments: #1 Declaration(s) supplemental emergency declaration, #2 Declaration(s) statement of Fraudulent receiver filings) (Crawford, Cassandra) Modified text on 8/1/2025 (knb). |
| Filing 22 Supplemental and Amended Emergency MOTION to Authorize Sale of Homestead Property and Enjoin City Interference filed by Cassandra Bryant Crawford. (Crawford, Cassandra) Modified text on 7/30/2025 (knb). |
| Filing 21 Emergency MOTION to Authorize Sale of Homestead Property and Enjoin City Interference filed by Cassandra Bryant Crawford. (Attachments: #1 Affidavit(s) Sole Ownership/Homestead, #2 Affidavit(s) Homestead Pg. 1., #3 Additional Page(s) Homestead Pg. 2, #4 Exhibit(s) Dallas CAD Listing of ownership, #5 Declaration(s) In Support of Emergency Motion) (Crawford, Cassandra) Modified text on 7/30/2025 (knb). |
| Filing 20 CERTIFICATE OF SERVICE by Cassandra Bryant Crawford re #19 Emergency MOTION to Compel Regulatory Compliance Mailing to Defendants on July 23, 2025 (Crawford, Cassandra) |
| Filing 19 Emergency MOTION to Compel Regulatory Clarification and to Suspend Receiver Enforcement filed by Cassandra Bryant Crawford with Brief/Memorandum in Support. (Attachments: #1 Declaration(s) In Suport of Cert of Occ. and Mediation, #2 Exhibit(s) Email from City Attorney suggesting Mediation) (Crawford, Cassandra) Modified text on 7/25/2025 (kxm). |
| Filing 18 Summons Issued as to Mark Adams, City of Dallas, Perry Kilgo, Other Unknown Agents, Isiah T Payne, Emily Worland. (knb) |
| Filing 17 Request for Clerk to issue Summons filed by Cassandra Crawford. (knb) |
| Filing 16 Emergency MOTION to Void Receiver Actions and Expunge Fraudulent Title Filings filed by Cassandra Crawford. (knb) |
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Filing 15
ORDER: For the foregoing reasons, Plaintiffs First TRO Motion [ECF No. #5 ], Motion to Void Receiver Certificate [ECF No. #9 ], and Second TRO Motion [ECF No. #10 ] are DENIED. (Ordered by Judge Karen Gren Scholer on 7/14/2025) (ndt)
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| ***Clerk's Notice of delivery: (see NEF for details) Docket No:15. Mon Jul 14 15:58:29 CDT 2025 (crt) |
| Filing 14 Public correspondence addressed to judge, received from Cassandra Crawford. (knb) |
| Filing 13 AMENDED COMPLAINT for Injunctive Relief against City of Dallas, Emily Worland, Mark Adams, Perry Kilgo, Other Unknown Agents filed by Cassandra Crawford. Unless exempted, attorneys who are not admitted to practice in the Northern District of Texas must seek admission promptly. Forms, instructions, and exemption information may be found at www.txnd.uscourts.gov, or by clicking here: # Attorney Information - Bar Membership. If admission requirements are not satisfied within 21 days, the clerk will notify the presiding judge. (knb) |
| Filing 12 MOTION for Preliminary Injunction filed by Cassandra Crawford. (knb) |
| Filing 11 Brief/Memorandum in Support filed by Cassandra Crawford re #10 Emergency MOTION for Temporary Restraining Order. (cfk) |
| Filing 10 Emergency MOTION for Temporary Restraining Order and Emergency Relief filed by Cassandra Crawford. (cfk) |
| Filing 9 Emergency MOTION to Void Receiver Certificate, Stop Unauthorized Sale, and Enjoin Enforcement Pending Hearing filed by Cassandra Crawford. (cfk) |
| ***Clerk's Notice of delivery: (see NEF for details) Docket No:8. Tue Jul 8 10:13:13 CDT 2025 (crt) |
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Filing 8
ELECTRONIC ORDER AND NOTICE OF DEFICIENCY: Having paid the filing fee, Plaintiff Cassandra Crawford is responsible for seeking issuance of summons and for service of process on the defendant(s) pursuant to Rule 4 of the Federal Rules of Civil Procedure. Plaintiff is placed on notice that service of process must be accomplished within 90 days of filing, unless good cause is shown, or this case may be dismissed. See Fed. R. Civ. P. 4(m). Further, a review of the docket reveals that Plaintiff has not yet registered as a user of the Court's electronic filing system, as required. In the event Plaintiff has not already done so, Plaintiff is ORDERED to register for electronic filing through this Court's CM/ECF system, as required by Northern District of Texas Local Civil Rule 5.1(f), by July 28, 2025. Instructions for registering are found online at #https://www.txnd.uscourts.gov/file-registration. FAILURE TO COMPLY WITH THIS ORDER MAY RESULT IN THE DISMISSAL OF THIS ACTION PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 41(b). (Ordered by Magistrate Judge Rene Harris Toliver on 7/7/2025) (chmb)
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| Filing 7 MOTION to Appoint Counsel filed by Cassandra Crawford. (knb) |
| Filing 6 Declaration re #5 MOTION for Temporary Restraining Order by Cassandra Crawford. (knb) |
| Filing 5 Emergency MOTION for Temporary Restraining Order and Emergency Relief filed by Cassandra Crawford. (knb) |
| Filing 4 MOTION for Preliminary Injunction filed by Cassandra Crawford. (knb) |
| Filing 3 COMPLAINT WITH JURY DEMAND against City of Dallas, Isiah T Payne filed by Cassandra Crawford. (Filing fee $405; Receipt number 300018631) Unless exempted, attorneys who are not admitted to practice in the Northern District of Texas must seek admission promptly. Forms, instructions, and exemption information may be found at www.txnd.uscourts.gov, or by clicking here: # Attorney Information - Bar Membership. If admission requirements are not satisfied within 21 days, the clerk will notify the presiding judge. (knb) |
| Filing 2 Notice and Instruction to Pro Se Party. (knb) |
| Filing 1 New Case Notes: A filing fee has been paid. CASREF case referral set and case referred to Magistrate Judge Toliver (see Special Order 3). Case received over counter or electronically. No prior sanctions found. (For court use only - links to the #national and #circuit indexes.) Pursuant to Misc. Order 6, Plaintiff is provided the Notice of Right to Consent to Proceed Before A U.S. Magistrate Judge (Judge Toliver). Clerk to provide copy to plaintiff if not received electronically. (knb) |
| ***Clerk's Notice of delivery: (see NEF for details) Docket No:1, 2. Mon Jul 7 15:44:11 CDT 2025 (crt) |
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