On June 06, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
Cano, Marina,
Cano, Michael,
and
Cobb, Clyde,
Cobb, Connie,
Codilis & Moody, P.C.,
Delaney, Thomas,
Demuth, Aaron,
Gladney, Danya,
Lewis, Constance,
Martin, Julie,
Mendoza, Alexis,
Mendoza, Arnold,
Mendoza, Sandra,
Selene Finance, Lp,
Servicelink Agency Sales And Posting, Llc,
U.S. Bank Trust National Association,
for Contract - Other Contract (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Filed
4/25/2023 12:49 PM
Hidalgo County District Clerks
Reviewed By: Krystal Hidalgo
CAUSE NO. C-2085-22-E
MICHAEL CANO and MARINA CANO § IN THE DISTRICT COURT
§
V. § HIDALGO COUNTY, TEXAS
§
SELENE FINANCE, LP and U.S. BANK §
TRUST NATIONAL ASSOCIATION, ET AL. § 275th JUDICIAL DISTRICT
EMERGENCY MOTION FOR
WRIT OF POSSESSION
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES SEER LABS, LLC, Intervenor in the above styled and
numbered cause, and files this its EMERGENCY MOTION FOR WRIT OF
POSSESSION, and would respectfully show unto the Court as follows:
On March 31, 2023, this Court entered a temporary injunction, requiring
Plaintiffs to leave the property in question. Plaintiffs were given fifteen (15) days to
do so.
The Hidalgo County Clerk’s Office sent the temporary injunction to all
counsel of record on April 6, 2023. Intervenor’s Counsel also forwarded a copy of the
injunction to Plaintiff’s counsel.
In this Court’s temporary injunction order, Plaintiffs have been given fifteen
(15) days to vacate the property. However, they have failed to do so.
Accordingly, Intervenors request that a writ of possession issue, and that the
Hidalgo County Sheriff’s Department commence removing Plaintiffs’ possession
from the house in question.
Intervenors further request that the deposit of $2000 by Plaintiffs into the
1
Electronically Filed
4/25/2023 12:49 PM
Hidalgo County District Clerks
Reviewed By: Krystal Hidalgo
registry of the Court be paid to them.
WHEREFORE, PREMISES CONSIDERED, SEER LABS, LLC, Intervenor in
the above styled and numbered cause, respectfully prays that a writ of possession
issue, that Plaintiffs be removed from the property in question by the Hidalgo
County Sheriff’s Department, and for all other and further relief, either at law or in
equity, to which Intervenor shows itself justly entitled.
Respectfully submitted,
LIVESAY LAW OFFICE
BRAZOS SUITES NO. 9
517 West Nolana
McAllen, Texas 78504
(956) 928-0149
Attorney@RGVAppellateLaw.com
BY: __/s/__Keith C. Livesay_________
KEITH C. LIVESAY
State Bar No. 12437100
CERTIFICATE OF SERVICE
I, KEITH C. LIVESAY, do hereby certify that I have caused to be delivered a
true and correct copy of the above and foregoing document by regular mail and/or
electronic delivery, to the following counsel of record:
Amanda A. Catlin
6900 Dallas Parkway, Suite 610
Plano, Texas 75024
Francisco J. Rodriguez
1111 West Nolana, Suite A
McAllen, Texas 78504
2
Electronically Filed
4/25/2023 12:49 PM
Hidalgo County District Clerks
Reviewed By: Krystal Hidalgo
Jason L. Sanders
325 N. St. Paul St., Suite 3100
Dallas, Texas 75201
On this the 17th day of April, 2023.
BY: __/s/__Keith C. Livesay_________
KEITH C. LIVESAY
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.
Keith Livesay on behalf of Keith Livesay
Bar No. 12437100
RGVAppellateLaw@yandex.com
Envelope ID: 74993834
Filing Code Description: Motion (No Fee)
Filing Description: EMERGENCY MOTION FOR WRIT OF POSSESSION
Status as of 4/25/2023 12:53 PM CST
Associated Case Party: MICHAEL CANO
Name BarNumber Email TimestampSubmitted Status
Francisco JRodriguez frankr@mcallenlawfirm.com 4/25/2023 12:49:36 PM SENT
Sonia Maupin sonia@mcallenlawfirm.com 4/25/2023 12:49:36 PM SENT
Danielle Rodriguez 24075952 danielle@mcallenlawfirm.com 4/25/2023 12:49:36 PM SENT
Jared A.Clark jared.clark@mcallenlawfirm.com 4/25/2023 12:49:36 PM SENT
Associated Case Party: SEER LABS, LLC
Name BarNumber Email TimestampSubmitted Status
Marcela Castillo magarcialaw2@yahoo.com 4/25/2023 12:49:36 PM SENT
Associated Case Party: MARINA CANO
Name BarNumber Email TimestampSubmitted Status
Gregory Brewer gregory.brewer@fnf.com 4/25/2023 12:49:36 PM SENT
Amanda A.Catlin amanda.catlin@fnf.com 4/25/2023 12:49:36 PM SENT
Fred Egler fred.egler@svclnk.com 4/25/2023 12:49:36 PM SENT
JASON SANDERS jsanders@sanderscollins.com 4/25/2023 12:49:36 PM SENT
Regina L.Carrell rcarrell@sanderscollins.com 4/25/2023 12:49:36 PM SENT
Gena Taylor gtaylor@sanderscollins.com 4/25/2023 12:49:36 PM SENT
Zulma Rosa zulma.rosa@fnf.com 4/25/2023 12:49:36 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
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.
Keith Livesay on behalf of Keith Livesay
Bar No. 12437100
RGVAppellateLaw@yandex.com
Envelope ID: 74993834
Filing Code Description: Motion (No Fee)
Filing Description: EMERGENCY MOTION FOR WRIT OF POSSESSION
Status as of 4/25/2023 12:53 PM CST
Case Contacts
AMANDA CATLIN Amanda.Catlin@fnf.com 4/25/2023 12:49:36 PM SENT
KEITH LIVESAY Paralegal@RGVAppellateLaw.com 4/25/2023 12:49:36 PM SENT
Associated Case Party: SELENE FINANCE, LP
Name BarNumber Email TimestampSubmitted Status
Jason Sanders jsanders@sanderscollins.com 4/25/2023 12:49:36 PM SENT
Caroline EAllen callen@sanderscollins.com 4/25/2023 12:49:36 PM SENT
Document Filed Date
April 25, 2023
Case Filing Date
June 06, 2022
Category
Contract - Other Contract (OCA)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Electronically Filed 4/25/2023 12:49 PM Hidalgo County District Clerks Reviewed By: Krystal Hidalgo CAUSE NO. C-2085-22-E MICHAEL CANO and MARINA CANO § IN THE DISTRICT COURT § V. § HIDALGO COUNTY, TEXAS § SELENE FINANCE, LP and U.S. BANK § TRUST NATIONAL ASSOCIATION, ET AL. § 275th JUDICIAL DISTRICT EMERGENCY MOTION FOR WRIT OF POSSESSION TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES SEER LABS, LLC, Intervenor in the above styled and numbered cause, and files this its EMERGENCY MOTION FOR WRIT OF POSSESSION, and would respectfully show unto the Court as follows: On March 31, 2023, this Court entered a temporary injunction, requiring Plaintiffs to leave the property in question. Plaintiffs were given fifteen (15) days to do so. The Hidalgo County Clerk’s Office sent the temporary injunction to all counsel of record on April 6, 2023. Intervenor’s Counsel also forwarded a copy of the injunction to Plaintiff’s counsel. In this Court’s temporary injunction order, Plaintiffs have been given fifteen (15) days to vacate the property. However, they have failed to do so. Accordingly, Intervenors request that a writ of possession issue, and that the Hidalgo County Sheriff’s Department commence removing Plaintiffs’ possession from the house in question. Intervenors further request that the deposit of $2000 by Plaintiffs into the 1 Electronically Filed 4/25/2023 12:49 PM Hidalgo County District Clerks Reviewed By: Krystal Hidalgo registry of the Court be paid to them. WHEREFORE, PREMISES CONSIDERED, SEER LABS, LLC, Intervenor in the above styled and numbered cause, respectfully prays that a writ of possession issue, that Plaintiffs be removed from the property in question by the Hidalgo County Sheriff’s Department, and for all other and further relief, either at law or in equity, to which Intervenor shows itself justly entitled. Respectfully submitted, LIVESAY LAW OFFICE BRAZOS SUITES NO. 9 517 West Nolana McAllen, Texas 78504 (956) 928-0149 Attorney@RGVAppellateLaw.com BY: __/s/__Keith C. Livesay_________ KEITH C. LIVESAY State Bar No. 12437100 CERTIFICATE OF SERVICE I, KEITH C. LIVESAY, do hereby certify that I have caused to be delivered a true and correct copy of the above and foregoing document by regular mail and/or electronic delivery, to the following counsel of record: Amanda A. Catlin 6900 Dallas Parkway, Suite 610 Plano, Texas 75024 Francisco J. Rodriguez 1111 West Nolana, Suite A McAllen, Texas 78504 2 Electronically Filed 4/25/2023 12:49 PM Hidalgo County District Clerks Reviewed By: Krystal Hidalgo Jason L. Sanders 325 N. St. Paul St., Suite 3100 Dallas, Texas 75201 On this the 17th day of April, 2023. BY: __/s/__Keith C. Livesay_________ KEITH C. LIVESAY 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. Keith Livesay on behalf of Keith Livesay Bar No. 12437100 RGVAppellateLaw@yandex.com Envelope ID: 74993834 Filing Code Description: Motion (No Fee) Filing Description: EMERGENCY MOTION FOR WRIT OF POSSESSION Status as of 4/25/2023 12:53 PM CST Associated Case Party: MICHAEL CANO Name BarNumber Email TimestampSubmitted Status Francisco JRodriguez frankr@mcallenlawfirm.com 4/25/2023 12:49:36 PM SENT Sonia Maupin sonia@mcallenlawfirm.com 4/25/2023 12:49:36 PM SENT Danielle Rodriguez 24075952 danielle@mcallenlawfirm.com 4/25/2023 12:49:36 PM SENT Jared A.Clark jared.clark@mcallenlawfirm.com 4/25/2023 12:49:36 PM SENT Associated Case Party: SEER LABS, LLC Name BarNumber Email TimestampSubmitted Status Marcela Castillo magarcialaw2@yahoo.com 4/25/2023 12:49:36 PM SENT Associated Case Party: MARINA CANO Name BarNumber Email TimestampSubmitted Status Gregory Brewer gregory.brewer@fnf.com 4/25/2023 12:49:36 PM SENT Amanda A.Catlin amanda.catlin@fnf.com 4/25/2023 12:49:36 PM SENT Fred Egler fred.egler@svclnk.com 4/25/2023 12:49:36 PM SENT JASON SANDERS jsanders@sanderscollins.com 4/25/2023 12:49:36 PM SENT Regina L.Carrell rcarrell@sanderscollins.com 4/25/2023 12:49:36 PM SENT Gena Taylor gtaylor@sanderscollins.com 4/25/2023 12:49:36 PM SENT Zulma Rosa zulma.rosa@fnf.com 4/25/2023 12:49:36 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status 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. Keith Livesay on behalf of Keith Livesay Bar No. 12437100 RGVAppellateLaw@yandex.com Envelope ID: 74993834 Filing Code Description: Motion (No Fee) Filing Description: EMERGENCY MOTION FOR WRIT OF POSSESSION Status as of 4/25/2023 12:53 PM CST Case Contacts AMANDA CATLIN Amanda.Catlin@fnf.com 4/25/2023 12:49:36 PM SENT KEITH LIVESAY Paralegal@RGVAppellateLaw.com 4/25/2023 12:49:36 PM SENT Associated Case Party: SELENE FINANCE, LP Name BarNumber Email TimestampSubmitted Status Jason Sanders jsanders@sanderscollins.com 4/25/2023 12:49:36 PM SENT Caroline EAllen callen@sanderscollins.com 4/25/2023 12:49:36 PM SENT