On June 25, 2020 a
Stipulation,Agreement
was filed
involving a dispute between
Johnson, Candi,
and
Esqueda, Raul Reyes,
Reyes, Eric,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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FILED
6/30/2021 1:39 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Lafonda Sims DEPUTY
CAUSE NO. DC-20-08741
CANDI JOHNSON § IN THE DISTRICT COURT
Plainnffi §
§
v. §
§ 44TH JUDICIAL DISTRICT
§
§
RAUL REYES ESQUEDA AND §
ERIC REYES §
Defendants. § DALLAS COUNTY, TEXAS
AGREED MOTION TO LIFT AUTOMATIC STAY
COMES NOW Defendants Raul Reyes Esqueda and Eric Reyes and Plaintiff Candi
Johnson, filing this Agreed Motion to Lift the Automatic Stay and reinstate this lawsuit to the
Court’s active docket, as follows:
1. Defendants’ insurance carrier, ACCC Insurance Company (“ACCC”), was
declared insolvent by the Texas Commissioner of Insurance on December 30, 2020. As such, this
lawsuit is subject to the Texas Property and Casualty Insurance Guaranty Act (TPCIGA), TEX.
INS. CODE § 462.001 et seq. Pursuant to TEX. INS. CODE § 462.309, this matter was automatically
stayed from action for a period of six months to expire on June 30, 2021. Notice of the automatic
stay was filed with the Court on December 22, 2020.
2. The statutory stay period has now expired, and the parties wish for this matter to be
reinstated to the Court’s active docket.
3. Both Plaintiff and Defendants agree to the lifting of the stay and reinstatement to
the Court’s docket.
Agreed Motion to LiftAutomatic Stay (145.0053) Page 1 of 3
WHEREFORE, the parties pray the Court grant this Agreed Motion to Lift Automatic Stay,
reinstate this case to the Court’s active docket, and set this matter for trial.
Respectfully submitted,
THE WILLIS LAW GROUP
/s/ Adam C. Gallegos
ADAM C. GALLEGOS
State Bar No. 24036614
RYAN L. RUSSO
State Bar No. 24088341
KIRK D. WILLIS
State Bar No. 21648500
1985 Forest Lane
Garland, Texas 75240
Telephone: 214-736-9433
Facsimile: 214-736-9994
E-Service only: service@thewillislawgroupcom
ATTORNEYS FOR DEFENDAN TS
RAUL REYES ESQUEDA AND ERIC REYES
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing document
was forwarded to all counsel of record, pursuant to the Texas Rules of Civil Procedure on the 30TH
day of June 2021.
Via E-Service: richard@stuckvlaw.com
Richard A. Stucky
SBN 24041986
Law Office of Richard A. Stucky
12700 Park Central Drive, Suite 1900
Dallas, Texas 75251
Phone: 214-453-1190
Fax: 214-308-2899
ATTORNEY FOR PLAINTIFF
/s/ Adam C. Gallegos
Adam C. Gallegos
Agreed Motion to Lift Automatic Stay (145.0053) Page 2 of 3
CERTIFICATE OF CONFERENCE
On June 23, 2021 the undersigned attorney spoke with Richard A. Stucky, counsel for
Plaintiff, to discuss the foregoing motion. Counsel indicated they were in agreement with the relief
sought herein, which is presented to the Court for entry.
/s/ Adam C. Gallegos
ADAM C. GALLEGOS
Agreed Motion to LiftAutomatic Stay (145.0053) Page 3 of 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.
Melissa Coleman on behalf of Adam Gallegos
Bar No. 24036614
mcoleman@thewillislawgroup.com
Envelope ID: 54934901
Status as of 7/2/2021 9:40 AM CST
Associated Case Party: CANDI JOHNSON
Name BarNumber Email TimestampSubmitted Status
Richard Allan Stucky 24041986 Richard@stuckylaw.com 6/30/2021 1:39:46 PM SENT
Jose Martinez Jose@stuckylaw.com 6/30/2021 1:39:46 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
KIP PETROFF kris@kippetroff.com 6/30/2021 1:39:46 PM SENT
Associated Case Party: RAULREYESESQUEDA
Name BarNumber Email TimestampSubmitted Status
Adam C.Gallegos service@thewillislawgroup.com 6/30/2021 1:39:46 PM SENT
William Ward Alexander 24005625 william.alexander.jr@gmail.com 6/30/2021 1:39:46 PM SENT
Nora Casillas ncasillas@zalaw.net 6/30/2021 1:39:46 PM SENT
Document Filed Date
June 30, 2021
Case Filing Date
June 25, 2020
Category
MOTOR VEHICLE ACCIDENT
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FILED 6/30/2021 1:39 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Lafonda Sims DEPUTY CAUSE NO. DC-20-08741 CANDI JOHNSON § IN THE DISTRICT COURT Plainnffi § § v. § § 44TH JUDICIAL DISTRICT § § RAUL REYES ESQUEDA AND § ERIC REYES § Defendants. § DALLAS COUNTY, TEXAS AGREED MOTION TO LIFT AUTOMATIC STAY COMES NOW Defendants Raul Reyes Esqueda and Eric Reyes and Plaintiff Candi Johnson, filing this Agreed Motion to Lift the Automatic Stay and reinstate this lawsuit to the Court’s active docket, as follows: 1. Defendants’ insurance carrier, ACCC Insurance Company (“ACCC”), was declared insolvent by the Texas Commissioner of Insurance on December 30, 2020. As such, this lawsuit is subject to the Texas Property and Casualty Insurance Guaranty Act (TPCIGA), TEX. INS. CODE § 462.001 et seq. Pursuant to TEX. INS. CODE § 462.309, this matter was automatically stayed from action for a period of six months to expire on June 30, 2021. Notice of the automatic stay was filed with the Court on December 22, 2020. 2. The statutory stay period has now expired, and the parties wish for this matter to be reinstated to the Court’s active docket. 3. Both Plaintiff and Defendants agree to the lifting of the stay and reinstatement to the Court’s docket. Agreed Motion to LiftAutomatic Stay (145.0053) Page 1 of 3 WHEREFORE, the parties pray the Court grant this Agreed Motion to Lift Automatic Stay, reinstate this case to the Court’s active docket, and set this matter for trial. Respectfully submitted, THE WILLIS LAW GROUP /s/ Adam C. Gallegos ADAM C. GALLEGOS State Bar No. 24036614 RYAN L. RUSSO State Bar No. 24088341 KIRK D. WILLIS State Bar No. 21648500 1985 Forest Lane Garland, Texas 75240 Telephone: 214-736-9433 Facsimile: 214-736-9994 E-Service only: service@thewillislawgroupcom ATTORNEYS FOR DEFENDAN TS RAUL REYES ESQUEDA AND ERIC REYES CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing document was forwarded to all counsel of record, pursuant to the Texas Rules of Civil Procedure on the 30TH day of June 2021. Via E-Service: richard@stuckvlaw.com Richard A. Stucky SBN 24041986 Law Office of Richard A. Stucky 12700 Park Central Drive, Suite 1900 Dallas, Texas 75251 Phone: 214-453-1190 Fax: 214-308-2899 ATTORNEY FOR PLAINTIFF /s/ Adam C. Gallegos Adam C. Gallegos Agreed Motion to Lift Automatic Stay (145.0053) Page 2 of 3 CERTIFICATE OF CONFERENCE On June 23, 2021 the undersigned attorney spoke with Richard A. Stucky, counsel for Plaintiff, to discuss the foregoing motion. Counsel indicated they were in agreement with the relief sought herein, which is presented to the Court for entry. /s/ Adam C. Gallegos ADAM C. GALLEGOS Agreed Motion to LiftAutomatic Stay (145.0053) Page 3 of 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. Melissa Coleman on behalf of Adam Gallegos Bar No. 24036614 mcoleman@thewillislawgroup.com Envelope ID: 54934901 Status as of 7/2/2021 9:40 AM CST Associated Case Party: CANDI JOHNSON Name BarNumber Email TimestampSubmitted Status Richard Allan Stucky 24041986 Richard@stuckylaw.com 6/30/2021 1:39:46 PM SENT Jose Martinez Jose@stuckylaw.com 6/30/2021 1:39:46 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status KIP PETROFF kris@kippetroff.com 6/30/2021 1:39:46 PM SENT Associated Case Party: RAULREYESESQUEDA Name BarNumber Email TimestampSubmitted Status Adam C.Gallegos service@thewillislawgroup.com 6/30/2021 1:39:46 PM SENT William Ward Alexander 24005625 william.alexander.jr@gmail.com 6/30/2021 1:39:46 PM SENT Nora Casillas ncasillas@zalaw.net 6/30/2021 1:39:46 PM SENT