Preview
Electronically Submitted
10/1/2018 11:20 AM
Hidalgo County Clerk
Accepted by: Samantha Martinez
CAUSE NO. CL-18-2676-B
ENRIQUE CARREON, Plaintiff § IN THE COUNTY COURT
§
vs. §
§ COUNTY COURT AT LAW 2
ALBERTO EDUARDO ARJONA §
LOPEZ AND ALL §
OCCUPANTS/AND OR TENANTS, §
Defendant § HIDALGO COUNTY, TEXAS
PLAINTIFF'S MOTION FOR ATTORNEYS' FEES
Plaintiff, Enrique Carreon, through the undersigned attorney, files this motion for an
order to award reasonable court costs, including attorneys' fees, to plaintiff, and shows:
1. Undersigned Attorney was retained to represent plaintiff in the above action and
has represented plaintiff in all proceedings, hearings, and other matters through the conclusion of
the above litigation.
2. On September 18, 2018, Plaintiff was awarded a Judgment against Defendants for
unpaid rent and late fees. Additionally, Plaintiff was awarded possession of his property located
at 3404 San Andres, Mission, Texas 78572.
3. On September 19, 2018, Counsel for Plaintiff sent a letter to Defendants, by and
through their attorney of record, advising of the 10 days given to vacate the premises.
4. On September 27, 2018, Counsel for Plaintiff sent another letter to Defendants, by
and through their attorney of record, advising of the move out date for September 28, 2018.
5. On September 27, 2018, Counsel for Plaintiff called and communicated to
Defendants counsel the necessity of following the judgment order and the agreement to vacate.
6. On September 28, 2018, Counsel for Plaintiff called and communicated to
Defendants counsel a reminder to vacate the premises and to turn over any keys or entry remotes
to the property.
Electronically Submitted
10/1/2018 11:20 AM
Hidalgo County Clerk
Accepted by: Samantha Martinez
7. As of Monday, October 1, 2018, Defendants have not vacated the premises nor
have they paid the money as part of the judgment.
8. Pursuant to the Texas Property Code, plaintiff, the party in whose favor a
judgment or decree has been rendered, may recover reasonable court costs, including attorneys'
fees, from the non-prevailing party/parties.
9. The costs incurred by plaintiffs are: $4,800.00.
10. The time spent upon this matter by counsel for plaintiff and fees charged for the
time are reasonable.
11. Plaintiff believes that unless an award for attorneys fees and costs is made against
Defendants, defendants will continue to ignore and disregard the orders of the Court and will
further delay the move out and payment award in detriment to Plaintiff and his property.
Respectfully submitted,
LAW OFFICES OF SERGIO MUÑOZ, JR., P.C.
1110 S. Closner
Edinburg, Texas 78539
Tel: 956.381.5555
Fax: 956.381.5563
Email: munozlawefile@gmail.com
By. /s/ Sergio Muñoz, Jr.
SERGIO MUÑOZ, JR.
State Bar No. 24058009
Attorney for Enrique Carreon
CERTIFICATE OF SERVICE
I hereby certify that the above motion was served on opposing counsel, Juan Angel
Guerra as per the electronic filing system.
/s/ Sergio Muñoz, Jr
SERGIO MUÑOZ, JR.
Preview
Electronically Submitted 10/1/2018 11:20 AM Hidalgo County Clerk Accepted by: Samantha Martinez CAUSE NO. CL-18-2676-B ENRIQUE CARREON, Plaintiff § IN THE COUNTY COURT § vs. § § COUNTY COURT AT LAW 2 ALBERTO EDUARDO ARJONA § LOPEZ AND ALL § OCCUPANTS/AND OR TENANTS, § Defendant § HIDALGO COUNTY, TEXAS PLAINTIFF'S MOTION FOR ATTORNEYS' FEES Plaintiff, Enrique Carreon, through the undersigned attorney, files this motion for an order to award reasonable court costs, including attorneys' fees, to plaintiff, and shows: 1. Undersigned Attorney was retained to represent plaintiff in the above action and has represented plaintiff in all proceedings, hearings, and other matters through the conclusion of the above litigation. 2. On September 18, 2018, Plaintiff was awarded a Judgment against Defendants for unpaid rent and late fees. Additionally, Plaintiff was awarded possession of his property located at 3404 San Andres, Mission, Texas 78572. 3. On September 19, 2018, Counsel for Plaintiff sent a letter to Defendants, by and through their attorney of record, advising of the 10 days given to vacate the premises. 4. On September 27, 2018, Counsel for Plaintiff sent another letter to Defendants, by and through their attorney of record, advising of the move out date for September 28, 2018. 5. On September 27, 2018, Counsel for Plaintiff called and communicated to Defendants counsel the necessity of following the judgment order and the agreement to vacate. 6. On September 28, 2018, Counsel for Plaintiff called and communicated to Defendants counsel a reminder to vacate the premises and to turn over any keys or entry remotes to the property. Electronically Submitted 10/1/2018 11:20 AM Hidalgo County Clerk Accepted by: Samantha Martinez 7. As of Monday, October 1, 2018, Defendants have not vacated the premises nor have they paid the money as part of the judgment. 8. Pursuant to the Texas Property Code, plaintiff, the party in whose favor a judgment or decree has been rendered, may recover reasonable court costs, including attorneys' fees, from the non-prevailing party/parties. 9. The costs incurred by plaintiffs are: $4,800.00. 10. The time spent upon this matter by counsel for plaintiff and fees charged for the time are reasonable. 11. Plaintiff believes that unless an award for attorneys fees and costs is made against Defendants, defendants will continue to ignore and disregard the orders of the Court and will further delay the move out and payment award in detriment to Plaintiff and his property. Respectfully submitted, LAW OFFICES OF SERGIO MUÑOZ, JR., P.C. 1110 S. Closner Edinburg, Texas 78539 Tel: 956.381.5555 Fax: 956.381.5563 Email: munozlawefile@gmail.com By. /s/ Sergio Muñoz, Jr. SERGIO MUÑOZ, JR. State Bar No. 24058009 Attorney for Enrique Carreon CERTIFICATE OF SERVICE I hereby certify that the above motion was served on opposing counsel, Juan Angel Guerra as per the electronic filing system. /s/ Sergio Muñoz, Jr SERGIO MUÑOZ, JR.