02-11-2008 - Motion - Consolidate CV - DC0401100 - 1497761 - MOTION - CONSOLIDATE

• 
• 
• 
• 
• 
• 

                        

						    Preview
                        
                        
                          @ @
CAUSE NO. 04-01100-M Fy L E D

CRAIG DYER, § IN THE DIS! ralet ct Bbbicy ig
§ 08
Plaintiff, § Lafons
§ ExAS
vs. §
§ 298™ JUDICIAL pistatirur,S
DYER CUSTOM INSTALLATION, INC. 8
(DCI), JOSEPH GEETING, §
SUSAN LAMBERT, RICHARD GEETING §
and LAURI GEETING, 8
§
Defendants. § DALLAS COUNTY, TEXAS
MOTION TO CONSOLIDATE

TO THE HONORABLE JUDGE OF SAID COURT:

COME NOW, Defendant DYER CUSTOM INSTALLATION, INC. (“DCI”), JOSEPH
GEETING, SUSAN LAMBERT, RICHARD GEETING and LAURI GEETING, (collectively,
“Defendants”) and file this their Motion to Consolidate, and in support of this motion would
show unto the Court the following:

I
INTRODUCTION

On or about November 15, 2006, Pro Plumbing and Appliance Installation, Inc. f/k/a
Dyer Custom Installation, Inc. (“Pro Plumbing”) filed suit against Craig Dyer, Melisa Contreras
and the Estate of Larry Dyer (collectively “Defendants”) in the 393% Judicial District Court of
Denton County, Texas. The lawsuit was styled Pro Plumbing and Appliance Installa…