On December 09, 2021 a
DEFENDANT'S MOTON TO APPOINT GUARDIAN AD LITEM (Matheny) - Motion to Appoint Guardian Ad Litem
was filed
involving a dispute between
Matheny, Karen,
and
Allstate Property & Casualty Insurance Company,
Vega, Rafael,
for Injury/Damage - Motor Vehicle
in the District Court of Smith County.
Preview
Electronically Filed
12/30/2021 3:05 PM
Penny Clarkston, Smith County District Clerk
Reviewed By: Penny Clarkston
CAUSE NO. 21-2905-A
KAREN MATHENY, AS SURVIVING § IN THE DISTRICT COURT
WIFE OF DUSTIN LEE MATHENY, §
AND ELSIE FILLYAW, LEGAL GUARDIAN§
OF H. L. M., A MINOR §
§
VS. § OF SMITH COUNTY, TEXAS
§
RAFAEL VEGA AND ALLSTATE §
PROPERTY AND CASUALTY INSURANCE §
COMPANY § 7TH JUDICIAL DISTRICT
DEFENDANT’S MOTION TO APPOINT GUARDIAN AD LITEM
TO THE HONORABLE JUDGE OF THIS COURT:
NOW COMES RAFAEL VEGA, Defendant in the above-entitled cause, and files this
Motion to Appoint Guardian Ad Litem, and would respectfully show unto the Court as follows:
I.
Karen Matheny, as Surviving Wife of Dustin Lee Matheny, and Elsie Fillyaw, legal
guardian of H. L. M., a minor, have brought suit.
II.
The parties have reached a settlement agreement. As the settlement involves a minor
child, Defendant requests that the Court appoint a guardian ad litem to serve in behalf of H. L.
M.
WHEREFORE, PREMISES CONSIDERED, Defendant, RAFAEL VEGA, respectfully
prays that this Honorable Court grant his motion to appoint guardian ad litem, that the Court
appoint a guardian ad litem to serve in behalf of the minor child, H. L. M., and that Defendant
have such other and further relief to which he may show himself justly entitled.
Respectfully submitted,
BLACK & SKAGGS, P.C.
103 Baylor Drive
Tyler, Texas 75703
Telephone: (903)593-9400
Telecopier: (903)593-9401
/s/ Dennis G. Black
DENNIS G. BLACK
State Bar No. 02369600
dblack@blackskaggs.com
JERAMY “JAMY” M. SKAGGS
State Bar No. 24013520
jskaggs@blackskaggs.com
ATTORNEYS FOR DEFENDANT,
RAFAEL VEGA
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing has been served
on all counsel this 30th day of December, 2021.
/s/ Dennis G. Black
DENNIS G. BLACK
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Teresa Williams on behalf of Dennis Black
Bar No. 02369600
teresaw@blackskaggs.com
Envelope ID: 60406504
Status as of 12/31/2021 7:39 PM CST
Associated Case Party: Rafael Vega
Name BarNumber Email TimestampSubmitted Status
Teresa Williams twilliams@blackskaggs.com 12/30/2021 3:05:33 PM SENT
Beth Myers bmyers@blackskaggs.com 12/30/2021 3:05:33 PM SENT
Dennis Black dblack@blackskaggs.com 12/30/2021 3:05:33 PM SENT
Griselda Kinard gkinard@blackskaggs.com 12/30/2021 3:05:33 PM SENT
Associated Case Party: Karen Matheny
Name BarNumber Email TimestampSubmitted Status
Ashley N.Ischy ashley@robertslawfirm.com 12/30/2021 3:05:33 PM SENT
Associated Case Party: Allstate Property & Casualty Insurance Company
Name BarNumber Email TimestampSubmitted Status
Jacqueline M.Houlette Jackie.Houlette@allstate.com 12/30/2021 3:05:33 PM SENT
Document Filed Date
December 30, 2021
Case Filing Date
December 09, 2021
Category
Injury/Damage - Motor Vehicle
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Electronically Filed 12/30/2021 3:05 PM Penny Clarkston, Smith County District Clerk Reviewed By: Penny Clarkston CAUSE NO. 21-2905-A KAREN MATHENY, AS SURVIVING § IN THE DISTRICT COURT WIFE OF DUSTIN LEE MATHENY, § AND ELSIE FILLYAW, LEGAL GUARDIAN§ OF H. L. M., A MINOR § § VS. § OF SMITH COUNTY, TEXAS § RAFAEL VEGA AND ALLSTATE § PROPERTY AND CASUALTY INSURANCE § COMPANY § 7TH JUDICIAL DISTRICT DEFENDANT’S MOTION TO APPOINT GUARDIAN AD LITEM TO THE HONORABLE JUDGE OF THIS COURT: NOW COMES RAFAEL VEGA, Defendant in the above-entitled cause, and files this Motion to Appoint Guardian Ad Litem, and would respectfully show unto the Court as follows: I. Karen Matheny, as Surviving Wife of Dustin Lee Matheny, and Elsie Fillyaw, legal guardian of H. L. M., a minor, have brought suit. II. The parties have reached a settlement agreement. As the settlement involves a minor child, Defendant requests that the Court appoint a guardian ad litem to serve in behalf of H. L. M. WHEREFORE, PREMISES CONSIDERED, Defendant, RAFAEL VEGA, respectfully prays that this Honorable Court grant his motion to appoint guardian ad litem, that the Court appoint a guardian ad litem to serve in behalf of the minor child, H. L. M., and that Defendant have such other and further relief to which he may show himself justly entitled. Respectfully submitted, BLACK & SKAGGS, P.C. 103 Baylor Drive Tyler, Texas 75703 Telephone: (903)593-9400 Telecopier: (903)593-9401 /s/ Dennis G. Black DENNIS G. BLACK State Bar No. 02369600 dblack@blackskaggs.com JERAMY “JAMY” M. SKAGGS State Bar No. 24013520 jskaggs@blackskaggs.com ATTORNEYS FOR DEFENDANT, RAFAEL VEGA CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing has been served on all counsel this 30th day of December, 2021. /s/ Dennis G. Black DENNIS G. BLACK Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Teresa Williams on behalf of Dennis Black Bar No. 02369600 teresaw@blackskaggs.com Envelope ID: 60406504 Status as of 12/31/2021 7:39 PM CST Associated Case Party: Rafael Vega Name BarNumber Email TimestampSubmitted Status Teresa Williams twilliams@blackskaggs.com 12/30/2021 3:05:33 PM SENT Beth Myers bmyers@blackskaggs.com 12/30/2021 3:05:33 PM SENT Dennis Black dblack@blackskaggs.com 12/30/2021 3:05:33 PM SENT Griselda Kinard gkinard@blackskaggs.com 12/30/2021 3:05:33 PM SENT Associated Case Party: Karen Matheny Name BarNumber Email TimestampSubmitted Status Ashley N.Ischy ashley@robertslawfirm.com 12/30/2021 3:05:33 PM SENT Associated Case Party: Allstate Property & Casualty Insurance Company Name BarNumber Email TimestampSubmitted Status Jacqueline M.Houlette Jackie.Houlette@allstate.com 12/30/2021 3:05:33 PM SENT