A Texas court told real estate investors: if your LLC agreements say no joint venture exists, you cannot claim otherwise.
The Business Court of Texas, Third Division, handed down the ruling on April 23, 2026. At the center of the dispute is the Reserve at Lake Travis, a mixed-use development in Travis County, Texas – and a falling out between two investors over how the whole thing was run.
Here is how it started. In early 2021, George Lake and Brett Jensen got together to discuss buying and managing the Reserve. They contemplated a structure where multiple LLCs would each own and operate different parts of the property. By May of that year, they had formed several entities, four of which sat at the heart of this dispute: Harbor Village – 2021, LLC, Hillside Cottages – 2021, LLC, Riverbend Club RE – 2021, LLC, and Riverbend Marina RE – 2021, LLC. Each one was governed by a written company agreement. Two entities co-managed the LLCs: Enosis Investments, owned by Lake, and Braverman Management, Inc., owned by Jensen. Enosis had the final say whenever the two managers could not agree. A third entity, Southfork Development Partners, LLC, tied to Jensen, held membership interests in the LLCs but did not manage any of them…