Stipulation,Agreement: CHRIS GREEN vs. ROBERT COLLINS et al

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                                Cause No. 09-17367 - & D

10 ROY 25

Curis’GREEN, Ty THE 2347 3DistRICT CouRT

  

Plaintiff,
v. ~—-Daulag COuNTy, TEXAS

Rosert J. COLLINS,

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Defendant.

PLAINTIFF’S AGREED FIRST MOTION FOR CONTINUANCE

Plaintiff move the Court for a continuance of the November 29, 2010 trial date and in
support would show as follows:

1. The present trial setting is only the second setting in this case.

2. Neither party appeared for the original trial setting because, in reliance on past
practice, they were not expressly called to trial. Plaintiffs counsel was, however, called to trial
in an older case in Rockwall on the same day. Regardless, this case was dismissed for want of
prosecution and only recently reinstated.

3. Plaintiff requires additional time to conduct discovery and prepare for trial.
Moreover, the parties have not mediated this dispute.

4, In addition to the foregoing, Plaintiffs’ counsel is set for trial in two other cases
the week of the 29" and both of those cases are older.

5. The continuance is sought in the interest of justice and not solely for delay.

6. Defendant is in agreement with the relief sought herein.

WHEREFORE, Plaintiff respectfully requests that the November 29, 2010 trial date be

vacated and the case be reset in the ordinary course of the court’s business.

PLAINTIFF’S AGREED FIRST MOTION FOR CONTINUANCE PaGe fState Bar #0
1801 N. Hampton, Ste. 370
Desoto, Texas 75115

(972) 291-9300

(972) 291-0636 Facsimile

ATTORNEYS FOR PLAINTIFF

AGREED:

See Attechouf

Robert J. Collins
CERTIFICATE OF SERVICE

On this 18" day of November 2010, a copy of the foregoing instrument was served on
Defendant as set forth below:

Via FACSIMILE (214) 580-7600
Robert J. Collins

1401 Elm St., Ste. 1800

Dallas, TX 75202

DEFENDANT, PRO SE

 

 

PLAINTIFF'S AGREED FIRST MOTION FOR CONTINUANCE PAGE 2Nov 18 2010 9:52AM HP LASERJET FAX :

 

Respectfully submitted,

David R Gibson

State Bar #07861220
1801 N, Hampton, Ste. 370
Desoto, Texas 75115

(972) 291-9300
(972) 291-0636 Facsimile
ATTORNEYS FOR PLAINTIFF
AGREED:
Robert Jlext—"—~

Lathe Cobre

Collins /-saesramss
Robert J. Collins

CERURICATE OF SERVICE

On this ___ day of November 2010, a copy of the foregoing instrument was served on
Defendant as set forth below:

¥ Ih 4) §80-7600

Robert J. Collins
140} Elm St., Ste. 1800
Dallas, TX 7$202

DEFENDANT, PRO SE

David R. Gibson

 

 

PLAINTIFF'S AGREED FIRST MOTION FOR CONTINUANCE Pacp2Telephone (972) 291-9300

ViA First CLASS MAIL

Clerk, 134” District Court
600 Commerce Street
Dallas, Texas 75202

THE GIBSON LAW GROUP

ATTORNEYS ATLAW
1801 N. HampTon Rb, ‘Ste. 370

DESoTosT ‘AS S1AS
ggahaas raise

 
  

my.lawycr@s eglobalnet
c ~ aot LERK Facsimile (972) 291-0636

ee DEPUTY
November 18, 2010

Re: — Chris Green v. Robert J. Collins and Robert J. Collins, P.C.
Cause No. 09-17367

Dear Clerk:

Please file the enclosed Plaintiff's First Agreed Motion for Continuance, present the
enclosed agreed order to the Court for consideration, and return the file-stamped copy of the
motion to me in the enclosed SASE.

Thank you.

ce: Defendant

Very truly yous,

avi ibson