On January 27, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Naser, Ahmed,
and
Negga, Bethelehem,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FlLED
9/1/2021 3:54 PM
FELICIA PITRE
DISTRICT CLERK
Darling Tellez DEPUTY
CAUSE NO. DC-20-01415
AHMED NASER § IN THE DISTRICT COURT
§
Plaintiff, §
§
v. § 134m JUDICIAL DISTRICT
DALLAS 00., TEXAS
§
BETHELEHEM NEGGA §
§
Defendant. § DALLAS COUNTY, TEXAS
UNOPPOSED MOTION FOR CONTINUAN CE
NOW COME, Bethelehem Negga (“Defendant”) and file this Unopposed Motion for
Continuance and respectfully show:
I. PROCEDURAL BACKGROUND
1. On January 27, 2020, Plaintiff filed his Original Petition in this lawsuit against
Defendant.
2. Defendant filed his Original Answer on March 18, 2020.
3. The case was placed into an automatic stay on December 23, 2020, when
Defendant’s insurance carrier went into receivership, and the Texas Property Casualty Insurance
Guaranty Act (“TPCIGA”) went into effect.
4. The stay expired on June 30, 2021.
5. This case is currently set for jury trial on September 7, 2021.
6. This matter is now governed by the Texas Property Casualty Insurance Guaranty
Act, Chapter 462 of the Texas Insurance code, and now other insurance is now available, and the
insurance information must be verified prior to settlement.
UNOPPOSED MOTION FOR CONTINUANCE (145.0004) Page 1
7. Palties are currently in discussion to comply with the Texas Property Casualty
Guaranty Act in an attempt to reach a settlement.
8. On August 31, 2021 Plaintiff’ s Counsel stated he did not oppose a motion for
continuance.
II. ARGUMENT & AUTHORITIES
9. Rule 5 of Texas Rules of Civil Procedure provides, in pertinent part, as follows:
When by . . . order of court an act is required or allowed to be done at or within a
specified time, the court for cause shown may, at any time in its discretion (a) with
or without motion or notice, order the period enlarged if application therefor is
made before the expiration of the period originally prescribed or as extended by a
previous order . . . .
TEX. R. CIV. P. 5.
10. Given the need for additional time to obtain other insurance information in an effort
to propound settlement, additional time is requested, and parties seek to set trial of January, 2022.
ll. The Parties’ request for continuance is not sought for delay, but so the interests of
justice may be properly served.
HI. PRAYER
For these reasons, the Defendant respectfully requests the Court to continue the current
trial setting to January, 2022, and enter the Unopposed Order submitted with this Motion.
UNOPPOSED MOTION FOR CONTINUANCE (145.0004) Page 2
Respectfully Submitted,
THE WILLIS LAW GROUP, PLLC
/s/ Matthew Savegh
ADAM C. GALLEGOS
State Bar No. 00796956
MATTHEW SAYEGH
State Bar No. 24104359
KIRK D. WILLIS
State Bar No. 21648500
1985 Forest Lane
Garland, Texas 75042
Telephone: 214-736-9433
Facsimile: 214-736-9994
E-Service only: service@thewillislawgroup.com
ATTORNEYS FOR THE DEFENDANT
QERTIFIQATE QF SERVI§2E
This is to certify that a true and correct copy of the above and foregoing document has
been forwarded to counsel of record on the 15‘ day of September 2021, in accordance with Rule
21a of the Texas Rules of Civil Procedure.
/s/ Matthew Savegh
Matthew Sayegh
ERTIFI ATE F FERE E
This is to certify that on August 31, 2021, Matthew Sayegh conferred with James Bauguss
III the counsel for the plaintiff who stated he was unopposed to a motion for continuance.
/s/ Matthew Savegh
Matthew Sayegh
UNOPPOSED MOTION FOR CONTINUANCE (145.0004) Page 3
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.
Desieray Brown on behalf of Matthew Sayegh
Bar No. 24104359
desieray24@gmail.com
Envelope ID: 56906651
Status as of 9/2/2021 2:53 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Adam CGallegos service@thewillislawgroup.com 9/2/2021 11:06:01 AM SENT
William Ward Alexander 24005625 william.alexander.jr@gmail.com 9/2/2021 11:06:01 AM SENT
Camilo Valencia 24110468 Camilo.Valencia@oag.texas.gov 9/2/2021 11:06:01 AM SENT
Francine Ly fly@dallascourts.org 9/2/2021 11:06:01 AM SENT
James Bauguss eservice@benabbott.com 9/2/2021 11:06:01 AM SENT
Associated Case Party: BETHELEHEM NEGGA
Name BarNumber Email TimestampSubmitted Status
Nora Casillas ncasillas@zalaw.net 9/2/2021 11:06:01 AM SENT
Matthew Sayegh service@thewillislawgroup.com 9/2/2021 11:06:01 AM SENT
Vanessa Martinez service@thewillislawgroup.com 9/2/2021 11:06:01 AM SENT
Associated Case Party: AHMED NASER
Name BarNumber Email TimestampSubmitted Status
Matthew Sayegh service@thewillislawgroup.com 9/2/2021 11:06:01 AM SENT
Document Filed Date
September 01, 2021
Case Filing Date
January 27, 2020
Category
MOTOR VEHICLE ACCIDENT
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FlLED 9/1/2021 3:54 PM FELICIA PITRE DISTRICT CLERK Darling Tellez DEPUTY CAUSE NO. DC-20-01415 AHMED NASER § IN THE DISTRICT COURT § Plaintiff, § § v. § 134m JUDICIAL DISTRICT DALLAS 00., TEXAS § BETHELEHEM NEGGA § § Defendant. § DALLAS COUNTY, TEXAS UNOPPOSED MOTION FOR CONTINUAN CE NOW COME, Bethelehem Negga (“Defendant”) and file this Unopposed Motion for Continuance and respectfully show: I. PROCEDURAL BACKGROUND 1. On January 27, 2020, Plaintiff filed his Original Petition in this lawsuit against Defendant. 2. Defendant filed his Original Answer on March 18, 2020. 3. The case was placed into an automatic stay on December 23, 2020, when Defendant’s insurance carrier went into receivership, and the Texas Property Casualty Insurance Guaranty Act (“TPCIGA”) went into effect. 4. The stay expired on June 30, 2021. 5. This case is currently set for jury trial on September 7, 2021. 6. This matter is now governed by the Texas Property Casualty Insurance Guaranty Act, Chapter 462 of the Texas Insurance code, and now other insurance is now available, and the insurance information must be verified prior to settlement. UNOPPOSED MOTION FOR CONTINUANCE (145.0004) Page 1 7. Palties are currently in discussion to comply with the Texas Property Casualty Guaranty Act in an attempt to reach a settlement. 8. On August 31, 2021 Plaintiff’ s Counsel stated he did not oppose a motion for continuance. II. ARGUMENT & AUTHORITIES 9. Rule 5 of Texas Rules of Civil Procedure provides, in pertinent part, as follows: When by . . . order of court an act is required or allowed to be done at or within a specified time, the court for cause shown may, at any time in its discretion (a) with or without motion or notice, order the period enlarged if application therefor is made before the expiration of the period originally prescribed or as extended by a previous order . . . . TEX. R. CIV. P. 5. 10. Given the need for additional time to obtain other insurance information in an effort to propound settlement, additional time is requested, and parties seek to set trial of January, 2022. ll. The Parties’ request for continuance is not sought for delay, but so the interests of justice may be properly served. HI. PRAYER For these reasons, the Defendant respectfully requests the Court to continue the current trial setting to January, 2022, and enter the Unopposed Order submitted with this Motion. UNOPPOSED MOTION FOR CONTINUANCE (145.0004) Page 2 Respectfully Submitted, THE WILLIS LAW GROUP, PLLC /s/ Matthew Savegh ADAM C. GALLEGOS State Bar No. 00796956 MATTHEW SAYEGH State Bar No. 24104359 KIRK D. WILLIS State Bar No. 21648500 1985 Forest Lane Garland, Texas 75042 Telephone: 214-736-9433 Facsimile: 214-736-9994 E-Service only: service@thewillislawgroup.com ATTORNEYS FOR THE DEFENDANT QERTIFIQATE QF SERVI§2E This is to certify that a true and correct copy of the above and foregoing document has been forwarded to counsel of record on the 15‘ day of September 2021, in accordance with Rule 21a of the Texas Rules of Civil Procedure. /s/ Matthew Savegh Matthew Sayegh ERTIFI ATE F FERE E This is to certify that on August 31, 2021, Matthew Sayegh conferred with James Bauguss III the counsel for the plaintiff who stated he was unopposed to a motion for continuance. /s/ Matthew Savegh Matthew Sayegh UNOPPOSED MOTION FOR CONTINUANCE (145.0004) Page 3 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. Desieray Brown on behalf of Matthew Sayegh Bar No. 24104359 desieray24@gmail.com Envelope ID: 56906651 Status as of 9/2/2021 2:53 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Adam CGallegos service@thewillislawgroup.com 9/2/2021 11:06:01 AM SENT William Ward Alexander 24005625 william.alexander.jr@gmail.com 9/2/2021 11:06:01 AM SENT Camilo Valencia 24110468 Camilo.Valencia@oag.texas.gov 9/2/2021 11:06:01 AM SENT Francine Ly fly@dallascourts.org 9/2/2021 11:06:01 AM SENT James Bauguss eservice@benabbott.com 9/2/2021 11:06:01 AM SENT Associated Case Party: BETHELEHEM NEGGA Name BarNumber Email TimestampSubmitted Status Nora Casillas ncasillas@zalaw.net 9/2/2021 11:06:01 AM SENT Matthew Sayegh service@thewillislawgroup.com 9/2/2021 11:06:01 AM SENT Vanessa Martinez service@thewillislawgroup.com 9/2/2021 11:06:01 AM SENT Associated Case Party: AHMED NASER Name BarNumber Email TimestampSubmitted Status Matthew Sayegh service@thewillislawgroup.com 9/2/2021 11:06:01 AM SENT