On April 12, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
415 Trenton, L.L.C. D B A Walk-On'S Sports Bistreaux,
Haidar, Walid,
and
G & G Closed Circuit Events, L.L.C.,
for CPRC Chapter 12
in the District Court of Hidalgo County.
Preview
Electronically Filed
4/4/2022 3:41 PM
Hidalgo County District Clerks
Reviewed By: Armando Hervert
CAUSE NO. C-1392-21-B
WALID HAIDAR, INDIVIDUALLY, AND § IN THE DISTRICT COURT
AS REPRESENTATIVE OF 415 §
TRENTON, L.L.C. D/B/A WALK-ON’S §
SPORTS BISTREAUX & BAR, §
§
Plaintiffs/Counter-Defendants, §
§
v. §
§
G&G CLOSED CIRCUIT EVENTS, L.L.C., §
§
Defendant/Counter-Plaintiff, § 93RD JUDICIAL DISTRICT
§
v. §
§
MOUSSA HAIDAR, INDIVIDUALLY, §
AND D/B/A WALK-ON’S SPORTS §
BISTREAUX & BAR, §
§
Third-Party Counter-Defendant. § HIDALGO COUNTY, TEXAS
REQUEST FOR AN EXPEDITED HEARING ON DEFENDANT’S
MOTION TO MODIFY, CORRECT, REFORM, AND/OR CLARIFY
Defendant G&G Closed Circuit Events, LLC (“G&G” or “Defendant”) files its Request
for an Expedited Hearing on Defendant’s Motion to Modify, Correct, Reform, and/or Clarify (the
“Hearing Request”) and respectfully requests that this Court set the motion for an expedited
hearing before the Court.
1. On March 30, 2022, Defendant filed its Defendant’s Motion to Modify, Correct,
Reform, and/or Clarify the Order Granting Plaintiff’s Motion for Reconsideration (“Motion to
Correct”) asking the Court to correct, modify, and/or clarify the Order Granting Plaintiff’s
Motion for Reconsideration as to the signature date. The Motion to Correct requires a hearing
before the Court.
DEFENDANT’S REQUEST FOR HEARING ON MOTION TO CORRECT ORDER Page 1
n:\210701\pdg\Request for Hrg – Mtn Correct
Electronically Filed
4/4/2022 3:41 PM
Hidalgo County District Clerks
Reviewed By: Armando Hervert
2. Further, because of the deadlines associated with the Motion to Correct on when
the Court can rule on the motions and when a party can appeal, Defendant requests an expedited
hearing date.
3. Contemporaneously with the filing of this request for hearing, Defendant will be
submitting a proposed Order Setting Expedited Hearing (on the Motion to Correct) for the Court
to consider, sign, and enter.
PRAYER
For these reasons, Defendant moves the Court to schedule and set an expedited hearing
so the Court can consider and rule on the merits of Defendant’s Motion to Correct. Defendant
further requests any further relief that it may be entitled to.
Respectfully submitted,
By: ______________________________________
David M. Diaz
State Bar of Texas identification number 24012528
LAW OFFICES OF DAVID DIAZ, PLLC
825 Watters Creek Blvd.
Building M, Suite 250
Allen, Texas 75013
Telephone number: (972) 996-4588
Email address: david@diazlawtx.com
ATTORNEY FOR DEFENDANT
G&G CLOSED CIRCUIT EVENTS, LLC
DEFENDANT’S REQUEST FOR HEARING ON MOTION TO CORRECT ORDER Page 2
n:\210701\pdg\Request for Hrg – Mtn Correct
Electronically Filed
4/4/2022 3:41 PM
Hidalgo County District Clerks
Reviewed By: Armando Hervert
CERTIFICATE OF SERVICE
Pursuant to TEX. R. CIV. P. 21 and 21a, I certify that a copy of this instrument was served
on the 4th day of April, 2022 as follows:
J. Michael Moore VIA ECF (ELECTRONIC COURT FILING NOTICE)
The Moore Law Firm
4900 North 10th Street, Suite E-2
McAllen, Texas 78504
Pablo Garza III P. VIA ECF (ELECTRONIC COURT FILING NOTICE)
GARZA LAW FIRM, P.C.
5429 N. 23rd Street, Suite D
McAllen, Texas 78504
ATTORNEYS FOR PLAINTIFFS
By: ___________________________________
David M. Diaz
DEFENDANT’S REQUEST FOR HEARING ON MOTION TO CORRECT ORDER Page 3
n:\210701\pdg\Request for Hrg – Mtn Correct
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.
David Diaz on behalf of David Diaz
Bar No. 24012528
DAVID@DIAZLAWTX.COM
Envelope ID: 63242764
Status as of 4/5/2022 8:53 AM CST
Associated Case Party: Walid Haidar
Name BarNumber Email TimestampSubmitted Status
Lit Docket lit-docket@moore-firm.com 4/4/2022 3:41:18 PM SENT
Kimberly Garcia kimberly@pgarzalaw.com 4/4/2022 3:41:18 PM SENT
E Service eservice@pgarzalaw.com 4/4/2022 3:41:18 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
david diaz david@diazlawtx.com 4/4/2022 3:41:18 PM SENT
J. MICHAEL MOORE docket@moore-firm.com 4/4/2022 3:41:18 PM SENT
Document Filed Date
April 04, 2022
Case Filing Date
April 12, 2021
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Electronically Filed 4/4/2022 3:41 PM Hidalgo County District Clerks Reviewed By: Armando Hervert CAUSE NO. C-1392-21-B WALID HAIDAR, INDIVIDUALLY, AND § IN THE DISTRICT COURT AS REPRESENTATIVE OF 415 § TRENTON, L.L.C. D/B/A WALK-ON’S § SPORTS BISTREAUX & BAR, § § Plaintiffs/Counter-Defendants, § § v. § § G&G CLOSED CIRCUIT EVENTS, L.L.C., § § Defendant/Counter-Plaintiff, § 93RD JUDICIAL DISTRICT § v. § § MOUSSA HAIDAR, INDIVIDUALLY, § AND D/B/A WALK-ON’S SPORTS § BISTREAUX & BAR, § § Third-Party Counter-Defendant. § HIDALGO COUNTY, TEXAS REQUEST FOR AN EXPEDITED HEARING ON DEFENDANT’S MOTION TO MODIFY, CORRECT, REFORM, AND/OR CLARIFY Defendant G&G Closed Circuit Events, LLC (“G&G” or “Defendant”) files its Request for an Expedited Hearing on Defendant’s Motion to Modify, Correct, Reform, and/or Clarify (the “Hearing Request”) and respectfully requests that this Court set the motion for an expedited hearing before the Court. 1. On March 30, 2022, Defendant filed its Defendant’s Motion to Modify, Correct, Reform, and/or Clarify the Order Granting Plaintiff’s Motion for Reconsideration (“Motion to Correct”) asking the Court to correct, modify, and/or clarify the Order Granting Plaintiff’s Motion for Reconsideration as to the signature date. The Motion to Correct requires a hearing before the Court. DEFENDANT’S REQUEST FOR HEARING ON MOTION TO CORRECT ORDER Page 1 n:\210701\pdg\Request for Hrg – Mtn Correct Electronically Filed 4/4/2022 3:41 PM Hidalgo County District Clerks Reviewed By: Armando Hervert 2. Further, because of the deadlines associated with the Motion to Correct on when the Court can rule on the motions and when a party can appeal, Defendant requests an expedited hearing date. 3. Contemporaneously with the filing of this request for hearing, Defendant will be submitting a proposed Order Setting Expedited Hearing (on the Motion to Correct) for the Court to consider, sign, and enter. PRAYER For these reasons, Defendant moves the Court to schedule and set an expedited hearing so the Court can consider and rule on the merits of Defendant’s Motion to Correct. Defendant further requests any further relief that it may be entitled to. Respectfully submitted, By: ______________________________________ David M. Diaz State Bar of Texas identification number 24012528 LAW OFFICES OF DAVID DIAZ, PLLC 825 Watters Creek Blvd. Building M, Suite 250 Allen, Texas 75013 Telephone number: (972) 996-4588 Email address: david@diazlawtx.com ATTORNEY FOR DEFENDANT G&G CLOSED CIRCUIT EVENTS, LLC DEFENDANT’S REQUEST FOR HEARING ON MOTION TO CORRECT ORDER Page 2 n:\210701\pdg\Request for Hrg – Mtn Correct Electronically Filed 4/4/2022 3:41 PM Hidalgo County District Clerks Reviewed By: Armando Hervert CERTIFICATE OF SERVICE Pursuant to TEX. R. CIV. P. 21 and 21a, I certify that a copy of this instrument was served on the 4th day of April, 2022 as follows: J. Michael Moore VIA ECF (ELECTRONIC COURT FILING NOTICE) The Moore Law Firm 4900 North 10th Street, Suite E-2 McAllen, Texas 78504 Pablo Garza III P. VIA ECF (ELECTRONIC COURT FILING NOTICE) GARZA LAW FIRM, P.C. 5429 N. 23rd Street, Suite D McAllen, Texas 78504 ATTORNEYS FOR PLAINTIFFS By: ___________________________________ David M. Diaz DEFENDANT’S REQUEST FOR HEARING ON MOTION TO CORRECT ORDER Page 3 n:\210701\pdg\Request for Hrg – Mtn Correct 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. David Diaz on behalf of David Diaz Bar No. 24012528 DAVID@DIAZLAWTX.COM Envelope ID: 63242764 Status as of 4/5/2022 8:53 AM CST Associated Case Party: Walid Haidar Name BarNumber Email TimestampSubmitted Status Lit Docket lit-docket@moore-firm.com 4/4/2022 3:41:18 PM SENT Kimberly Garcia kimberly@pgarzalaw.com 4/4/2022 3:41:18 PM SENT E Service eservice@pgarzalaw.com 4/4/2022 3:41:18 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status david diaz david@diazlawtx.com 4/4/2022 3:41:18 PM SENT J. MICHAEL MOORE docket@moore-firm.com 4/4/2022 3:41:18 PM SENT