On July 26, 2006 a
Motion,Ex Parte
was filed
involving a dispute between
and
for MODIFICATION-CUSTODY
in the District Court of Tarrant County.
Preview
231-405718-06 FILED
TARRANT COUNTY
7/9/2021 1:25 PM
THOMAS A. WILDER
DISTRICT CLERK
NO. 231-405718-06
IN THE INTEREST OF § IN THE DISTRICT COURT
§
LOGAN RYAN DAVIS § 231sT JUDICIAL DISTRICT
§
A CHILD § TARRANT COUNTY, TEXAS
MOTION FOR CONTINUANCE
This Motion for Continuance is brought by JOSEPH RYAN DAVIS, Respondent, who
shows in support:
1. A hearing for temporary orders is set in this case on July 12, 2021 at 10:30 a.m.
2. Respondent's counsel has not had sufficient time to prepare for the hearing in that
he has not obtained specific documents he believes are necessary and which may
significantly impact this case. Respondent requests that the temporary orders
hearing be continued until he obtains the documents.
3. Petitioner is currently the conservator with the right to designate the primary
residence of the child and therefore, would suffer no prejudice or harm if this
matter was continued.
4. This continuance is not sought solely for delay but so that justice may be done.
JOSEPH RYAN DAVIS, Respondent, prays that the Court grant the Motion for
Continuance.
Respectfully submitted,
MITCHELL LAW FIRM
3100 W. Southlake Blvd, Ste. 110
Southlake, TX 76092
Tel: (817) 554-0222
Fax: (817) 488-7504
By: Isl Rick J Mitchell
Rick J. Mitchell
State Bar No. 24060928
Alvin Q. Malone
State Bar No. 24085446
rmitchell.law@gmail.com
Attorneys for Respondent
Motion for Continuance Page 1 of3
Certificate of Conference
The undersigned certifies that his office spoke with opposing counsel, Alison Porterfield
regarding the merits of this motion and that is opposed. Therefore, this motion is presented to
the Court for determination.
Isl Rick J Mitchell
Rick J. Mitchell
Attorney for Respondent
Certificate of Service
I certify that a true and correct copy of this document was served in accordance with rule
21a of the Texas Rules of Civil Procedure on the following on July 9, 2021:
Alison Porterfield via electronic filing manager at alison@teamsl.com.
Isl Rick J Mitchell
Rick J. Mitchell
Attorney for Respondent
Motion for Continuance Page 2 of3
Verification
The undersigned states under oath: "I am the attorney for the movant in the foregoing
Motion for Continuance. I have read the motion. The statements contained in paragraph 2 in the
motion are within my personal knowledge and are true and correct".
Alvin Q. Malone
SIGNED under oath before me on July 9, 2021.
Notary Public, State of Texas
Motion for Continuance Page 3 of3
Document Filed Date
July 09, 2021
Case Filing Date
July 26, 2006
Category
MODIFICATION-CUSTODY
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
231-405718-06 FILED TARRANT COUNTY 7/9/2021 1:25 PM THOMAS A. WILDER DISTRICT CLERK NO. 231-405718-06 IN THE INTEREST OF § IN THE DISTRICT COURT § LOGAN RYAN DAVIS § 231sT JUDICIAL DISTRICT § A CHILD § TARRANT COUNTY, TEXAS MOTION FOR CONTINUANCE This Motion for Continuance is brought by JOSEPH RYAN DAVIS, Respondent, who shows in support: 1. A hearing for temporary orders is set in this case on July 12, 2021 at 10:30 a.m. 2. Respondent's counsel has not had sufficient time to prepare for the hearing in that he has not obtained specific documents he believes are necessary and which may significantly impact this case. Respondent requests that the temporary orders hearing be continued until he obtains the documents. 3. Petitioner is currently the conservator with the right to designate the primary residence of the child and therefore, would suffer no prejudice or harm if this matter was continued. 4. This continuance is not sought solely for delay but so that justice may be done. JOSEPH RYAN DAVIS, Respondent, prays that the Court grant the Motion for Continuance. Respectfully submitted, MITCHELL LAW FIRM 3100 W. Southlake Blvd, Ste. 110 Southlake, TX 76092 Tel: (817) 554-0222 Fax: (817) 488-7504 By: Isl Rick J Mitchell Rick J. Mitchell State Bar No. 24060928 Alvin Q. Malone State Bar No. 24085446 rmitchell.law@gmail.com Attorneys for Respondent Motion for Continuance Page 1 of3 Certificate of Conference The undersigned certifies that his office spoke with opposing counsel, Alison Porterfield regarding the merits of this motion and that is opposed. Therefore, this motion is presented to the Court for determination. Isl Rick J Mitchell Rick J. Mitchell Attorney for Respondent Certificate of Service I certify that a true and correct copy of this document was served in accordance with rule 21a of the Texas Rules of Civil Procedure on the following on July 9, 2021: Alison Porterfield via electronic filing manager at alison@teamsl.com. Isl Rick J Mitchell Rick J. Mitchell Attorney for Respondent Motion for Continuance Page 2 of3 Verification The undersigned states under oath: "I am the attorney for the movant in the foregoing Motion for Continuance. I have read the motion. The statements contained in paragraph 2 in the motion are within my personal knowledge and are true and correct". Alvin Q. Malone SIGNED under oath before me on July 9, 2021. Notary Public, State of Texas Motion for Continuance Page 3 of3