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Job Opening - EMMA Foundation

24 Mar 2025 11:58 AM | Lucy Cain (Administrator)

Case Summary – March 22, 2025

I am seeking an attorney (preferably a junior associate with under 5 years of experience) to

assist with a breach of debt payment contract arising from several failed real estate

investments. I am a LegalShield member and receive a 25% discount on the attorney’s hourly

rate.

Background:

We the Plaintiff, Party 1 (P1) – Munzer Haque Family Members, (“MHFM”) invested with P2

(defendant – syndicator/GP), who signed both personal and business guarantees, promising a

30% IRR in several real estate investments. After the properties were foreclosed in 2023–2024,

this was restructured into a 6-year debt repayment contract, which P2 breached on August 1,

2024. I do not have an exact dollar figure yet, but the investment amount exceeds several

hundred thousand dollars. The lawsuit is already drafted. After your necessary revision this case

needs to be filed with Harris County District Court, TX.

Legal Objectives:

1. Filling the main lawsuit, motion for non-dischargeable summary judgment (main

objective), based on bad-faith intent

2. Motions for injunction, and Urgent Intervention in Receivership (UIR)

3. Trial and hearing representation

4. Judgment enforcement strategy using behavioral economics

I have maintained strategic communication with P2 and obtained internal information that

strengthens the case and collection. A separate investor group (P3), consisting of 123 investors

in a different investment, has already secured judgment against the same P2 and begun

collection. Our claim is stronger and may even go uncontested.

This is a win-win opportunity—for a junior attorney eager to gain hands-on litigation

experience in an interesting media-covered case (WSJ, local TV & Newspapers, online) that can

elevate professional visibility for you and for your law firm.

I am not an attorney, but I understand the basics of legal process, very good in sequitur logical

argument, identify opposing party’s strawman argument, and applying behavioral economics—

useful in judgment collection or negotiating a new non-dischargeable debt re-schedule. To

know more about me you may visit www.EmmaFoundation.net

We are retired and lost our entire 40 years of 401(k) saving with P2. We can afford no more

than $250.00/hour for a junior associate attorney with modest retainer. We will always

replenish the retainer escrow in advance whenever needed.

Munzer Haque

972-971-5593

Munzer@OmnicureHomeHealth.com


ABOUT ASSOCIATION

The Houston Young Lawyers Association (HYLA) is a bar association of Houston young attorneys. Our membership consists of lawyers in their first twelve years of practice as of June 1, as well as law students. Our mission is to help our members learn, lead, network, and serve. Please check out our calendar for upcoming events, and our committees page to see how you can get involved!

CONTACTS

hyla@hyla.org
(713) 224-4952  

Lucy Fisher Cain (281) 685-9929

P.O. Box 61208

Houston, Texas  77208

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