Vicky Nicandros Elliot v Steve Nicandros et al21 Apr 2025 03:28
Pt 1
Cause No. 533554
Vicky Nicandros Elliot
v.
Steve Constantine Nicandros;
National Advisors Trust Company;
Mercer Global Advisors, Inc.;
Kanaly Trust Company;
Kanaly Trust LTA; and
Andrew Kanaly
In Probate Court No.
of Harris County, Texas
NO SERV REC
Plaintiff's Original Petition
Parties
1. Plaintiff Vicky Nicandros Elliot is an individual residing in the State of Tennessee.
2. Defendant Steve Constantine Nicandros is an individual residing in Houston, Texas, who may be served at 414 Pineneedle Drive, Houston, Texas 77024, or wherever he may be found.
3. Defendant National Advisors Trust Company ("NATCO") is a Missouri trust company doing business in the State of Texas, which may be served by and through its officers at its headquarters at 800 E. 101st Terrace, Suite 300, Kansas City, Missouri 64131, or wherever it may be found.
4. Defendant Mercer Global Advisors, Inc. is a Delaware corporation with its principal place of business in Houston, Texas. It may be served through its registered agent in Texas: National Registered Agents, Inc., 1999 Bryan St., Suite 900, Dallas, Texas 75201-3136, or wherever it may be found.
5. Defendant Kanaly Trust Company is a Texas trust company that may be served at 5555 San Felipe Road, Suite 200, Houston, Texas 77056, or wherever it may be found. It is unclear from available documents whether it survived a merger with Mercer and/or NATCO, so it is being joined here out of an abundance of caution.
6. Defendant Kanaly Trust, LTA (collectively, with Kanaly Trust Company, "Kanaly") is a Texas limited trust association that may be served at 5555 San Felipe Road, Suite 200, Houston, Texas 77056, or wherever it may be found. It is unclear from available documents whether it survived a merger with Mercer and/or NATCO, so it is being joined here out of an abundance of caution.
7. Defendant Andrew D. Kanaly is an individual residing in Houston, Texas, who may be served c/o Mercer Advisors at 5555 San Felipe Street, Suite 200, Houston, Texas 77056, or wherever he may be found.
Venue & Jurisdiction
8. This action is within the jurisdiction of the statutory probate courts because it involves trusts and is against purported trustees.
9. Venue is mandatory in Harris County, Texas because this action involves trusts administered in Harris County. Tex.
10. Venue is also proper in Harris County because all or a substantial part of the events or omissions giving rise to Plaintiff's causes of action occurred there and Defendants either resided in or had their principal Texas office in Harris County at the time the causes of action accrued.
11. The Court has jurisdiction over Defendants because they conduct business in Texas and a substantial part of the events or omissions giving rise to Plaintiff's claims occurred in Texas.