Response | Filed: June 16, 2026
| Entered: June 16, 2026
MG Road LLC et al v. Affiliated FM Insurance Company
Insurance | Georgia Northern
Response in Opposition to Motion
RESPONSE in Opposition re 46 MOTION for Summary Judgment filed by Banyan Tree Management, LLC, Columbus GA Hotel Partners I, LP, MG Road LLC. (Attachments: # 1 Statement of Material Facts Plaintiffs' Response to Defendant's Statement of Material Facts, # 2 Plaintiffs' Additional Statements of Material Facts, # 3 Appendix of Exhibits to Plaintiffs' Memorandum of Law, # 4 Exhibit 1 - MG Road LLC's Organizational Chart, # 5 Exhibit 2 - Columbus Partners' Organizational Chart, # 6 Exhibit 3 - Expert Report of Doug Sharpe, # 7 Exhibit 4 - Am. Compl. Ex. A - Policy issued by Affiliated FM Insurance Company, # 8 Exhibit 5 - Excerpts of Deposition of Thomas DeSousa, # 9 Exhibit 6 - January 3, 2023 Email from DeSousa to Crabtree, # 10 Exhibit 7 - January 3, 2023 Email from Crabtree to Oswald, # 11 Exhibit 8 - January 3, 2023 Email from Oswald to members of the Banyan management team, # 12 Exhibit 9 - December 30, 2022 Email from Blair to DeSousa, # 13 Exhibit 10 - January 5, 2023 Email from Blair to DeSousa re Coverage and Advanced Payment Confirmation, # 14 Exhibit 11 - January 10, 2023 Email from Blair to DeSousa re Coverage and Advanced Payment Confirmation, # 15 Exhibit 12 - January 12, 2023 Email from Crabtree to Lewellen and Oswald, # 16 Exhibit 13 - February 9, 2023 Crabtree's Email re assistance from the Policy broker, # 17 Exhibit 14 - Meeting between Blair and broker representatives, # 18 Exhibit 15 - March 1, 2023 Blair's Email confirming coverage, # 19 Exhibit 16 - AFM confirmation of coverage approved by Joshua Martinez, # 20 Exhibit 17 - Excerpts of Deposition of Joshua Martinez, # 21 Exhibit 18 - April 24, 2023 Blair's mistaken statement, #
Discovery | Filed: June 16, 2026
| Entered: June 16, 2026
MG Road LLC et al v. Affiliated FM Insurance Company
Insurance | Georgia Northern
Deposition
DEPOSITION of Banyan Tree Management, LLC by and through its Corporate Designee Charles Oswald taken on April 20, 2026 by Banyan Tree Management, LLC, Columbus GA Hotel Partners I, LP, MG Road LLC.(Ely, Shattuck)