Document for Townewest Homeowners Association, Inc. vs Kevin D. McInnis

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                                NO. 21-DCV-279917


TOWNEWEST         HOMEOWNERS                                               IN THE DISTRICT COURT OF
ASSOCIATION, INC.
                     Plaintiff
ve                                                                        FORT BEND COUNTY, TEXAS


KEVIN D. MCINNIS


                    Defendant                                                  240th JUDICIAL DISTRICT

                                      PLAINTIFF’S MOTION TO RETAIN

TO THE HONORABLE JUDGE OF SAID COURT:

        Comes now Townewest Homeowners Association, Inc., Plaintiffin the above entitled and numbered

cause, and files this its Motion to Retain and would respectfully show the Court as follows:

                                                       I

        This is a suit based on delinquent maintenance assessments.

                                                       I.

        Defendant Kevin D. McInnis has not yet been served with citation herein, but Plaintiff continues its

diligent efforts to obtain service.

                                                      Il.

        Further, Plaintiff has been advised by its counsel that Counsel is closing its law office and has

advised Plaintiff to seek new counsel for Plaintiff's cases including this case. Counsel will prepare Motions

to Withdraw or Substitute in all of Counsel’s active litigation files, including this one.

                                                      IV.

        Plaintiff respectfully requests the Court to retain this case on its docket so that Plaintiff may pursue

its case against the Defendant, and be able to secure new trial counsel.
Vv

        This Motion to Retain is not made for purposes of delay, but that justice may be done.

       WHEREFORE, PREMISES CONSIDERED, Plaintiffrespectfully requests that this case be retained

on this Court’s docket until such time as this case is tried on its merits, and for such other and further relief,

in law or in equity, as Plaintiff may be justly entitled to receive.

                                                      Respectfully submitted,

                                                      THE LAW OFFICE OF
                                                      LEWIS W. “CHIP? SMITH IV, P.L.L.C.

                                                        -

                                                      L       w.)'cifP" SMITH        IV
                                                      Tl as Bar No. 00794656
                                                      Attorney for Plaintiff
                                                      7002 Riverbrook Drive, Suite 900-F
                                                      Sugar Land, Texas 77479
                                                      Telephone:   (281) 937-7021
                                                      Telefax: (281) 937-7493
                                                      Our File No. 950.203-20
//mb