3S Real Estate Investments, LLC ("3S") is a series LLC that Adam Sinn ("Sinn") uses to invest in real estate. Series 3 was designated to purchase Sinn's home in Houston in 2016 for ~$1.3M.

Shortly after that purchase, Sinn retained a contractor to add an outdoor grilling area to the house. This project was managed by Paul Sarver, who is Sinn’s friend. By not properly following construction laws, one subcontractor, ABG General Construction, ended up not getting paid for his work. The amount in dispute was trivial for Sinn: $4,000.

In January 2017, the subcontractor sent a demand letter, but Sinn refused to pay the invoice. After some back and forth between the subcontractor’s lawyer and Barry Hammond (as General Counsel of 3S), the subcontractor sued in June of 2018. Barry Hammond represented 3S in court and his legal strategy was based on dilatory tactics and misleading the court, echoing other litigation that Sinn has been involved in. 

Plaintiff’s counsel’s made a reasonable request to Barry Hammond: 

• “Please note this is not my only case. I have over 20 staff and over 3000 active clients. I cannot turn around stuff for you in a matter of hours. Please be patient. I am more than happy to work with you, but with all due respect, I can not place this matter as a life and death immediate attention unless there is a valid reason why it is needed.” 

Yet, Barry Hammond fired off multiple emails over the following few hours, which prompted Plaintiff's Counsel to comment on the unprofessional behavior: 

• “You are digging the attorney fee hole deeper and deeper every time you file non-sense motions.”
• “On a further note instead of rushing to Court for not getting a response in a matter of minutes I suggest you simply wait a couple days or send a follow up email. Note if you keep this up I will be filing for sanctions against you for not conferring as required by rules. I have already addressed this very issue with you in past.”

Defendant 3S finally settled in late 2018, after the subcontractor obtained a mechanic’s lien on the property, which could eventually allow him to foreclose on the property. 

In summary: Sinn opted to litigate for nearly 2 years, rather than paying a $4,000 invoice for work and services performed by a construction worker. And Sinn only finally paid what he owed once he was backed into a corner by the threat of the liquidation of his home.