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FILED
1/20/2023 11:38 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Jenifer Trujillo DEPUTY
CAUSE NO. DC-21-17449
REYES GROUP, LTD, § IN THE DISTRICT COURT
PLAINTIFF, §
§
vs. § 101ST DISTRICT COURT
§
ELK ENGINEERING ASSOCIATES, §
INC., §
DEFENDANT. § DALLAS COUNTY, TEXAS
THIRD-PARTY DEFENDANT BK CORROSION LLC’S UNOPPOSED FIRST
MOTION FOR CONTINUANCE
TO THE HONORABLE JUDGE OF SAID COURT:
Third-Party Defendant BK Corrosion, LLC files this its Unopposed First Motion for
Continuance, and as grounds therefore would show the Court the following:
I.
This case is set for trial on March 7, 2023. This is the first trial setting. This is the first Motion
for Continuance. Counsel for Plaintiff and Counsel for Defendant do not oppose this Motion.
II.
This case was originally filed on December 6, 2021. Defendant Elk Engineering Associates,
Inc. filed its Answer on February 14, 2022. On December 1, 2022, Defendant filed its Third-Party
Petition. Third-Party Defendant BK Corrosion, LLC has timely filed its Answer to Third-Party
Petition on January 20, 2023, the date of the filing of this Motion.
This Third-Party Defendant needs time to conduct discovery in this case in order to defend
itself and determine the allegations against it. Therefore, a continuance of the trial setting for sufficient
time for this party to prepare for trial is requested. This party requests a continuance of no less
than 180 days. This Motion is not made for solely for the purpose of delay but rather that justice be
done.
THIRD-PARTY DEFENDANT’S MOTION FOR CONTlNUAN CE l
WI-IEREFORE, PREMISES CONSIDERED, Third-Party Defendant BK Corrosion, LLC
prays that the Court continue this cause from its present trial setting of March 7, 2023 to some later
term of Court to be determined by the Court and to such and other and further relief at law or in equity.
Respectfully Submitted,
.AYIK & ASSOCIATES
/s/ Shelly S. Jock
SHELLY S. JOCK
Texas Bar No. 00794026
E-Mail: sjock@travelers.com
Mailing Address:
P.O. Box 64093
St. Paul, MN 55164-0093
Physical Address
1301 E. Collins Blvd, Suite 290
Richardson, Texas 75081
Direct Telephone: 214-200-2292
Main Telephone: 214-570-6300
ATTORNEYS FOR THIRD-PARTY
DEFENDANT BK CORROSION, LLC
THIRD-PARTY DEFENDANT’S MOTION FOR CONTlNUAN CE
DECLARATION OF SHELLY S. JOCK
I, Shelly S. Jock, have personal knowledge of facts stated herein and certify that they are true and
correct to best of my knowledge.
/s/ Shell S. Jock
SHELLY SJOCK
CERTIFICATE OF CONFERENCE
Third-Party Defendant's counsel has conferred with the attorneys in this cause and agreement has
been reached, and therefore it is requested that this matter be granted.
/s/ Shelly S. Jock
Shelly S. Jock
CERTIFICATE OF SERVICE
This is to certify that, on this the 20th day of January, 2023, a true and correct copy of the
foregoing document was forwarded to all counsel of record as follows Via eservice.
Curtis Hubbard Hand Delivery
Nixon Jach Hubbard, PLLC Facsimile
14241 Dallas Parkway, Suite 575 Certified Mail, Return Receipt Requested
Dallas, TX 75245 Receipted Commercial Delivery
Facsimile 972-503- 7001 Regular U.S. Mail
Attorney for Plaintiflf x E-service
Reyes Group, Ltd
Angela D. Caffey Hand Delivery
Thompson, Coe, Cousins & Irons, LLP Facsimile
700 N. Pearl Street, 25th Floor Certified Mail, Return Receipt Requested
Dallas, TX 75201 Receipted Commercial Delivery
Attorney for Defendant, Elk Engineering Regular U.S. Mail
Associates, Inc. x E-service
/s/ Shelly S. Jock
Shelly S. Jock
THIRD-PARTY DEFENDANT’S MOTION FOR CONTlNUAN CE
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.
Donna Pitek on behalf of Shelly Jock
Bar No. 794026
dpitek@travelers.com
Envelope ID: 71982407
Status as of 1/20/2023 12:13 PM CST
Associated Case Party: ELK ENGINEERING ASSOCIATES, INC.
Name BarNumber Email TimestampSubmitted Status
Daniel PBuechler dbuechler@thompsoncoe.com 1/20/2023 11:38:11 AM SENT
Angela DCaffey acaffey@thompsoncoe.com 1/20/2023 11:38:11 AM SENT
Lindsey Robison Irobison@thompsoncoe.com 1/20/2023 11:38:11 AM SENT
Susan Dyess sdyess@thompsoncoe.com 1/20/2023 11:38:11 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Cathy Schmitz cschmitz@thompsoncoe.com 1/20/2023 11:38:11 AM SENT
101st District Court 101court@dallascounty.org 1/20/2023 11:38:11 AM SENT
Laura Deen |deen@njh-Iaw.com 1/20/2023 11:38:11 AM SENT
CURTIS HUBBARD chubbard@njh-law.com 1/20/2023 11:38:11 AM SENT
Associated Case Party: BK Corrosion, LLC
Name BarNumber Email Timestam pSubmitted Status
Shelly S.Jock sjock@travelers.com 1/20/2023 11:38:11 AM SENT
Preview
FILED 1/20/2023 11:38 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Jenifer Trujillo DEPUTY CAUSE NO. DC-21-17449 REYES GROUP, LTD, § IN THE DISTRICT COURT PLAINTIFF, § § vs. § 101ST DISTRICT COURT § ELK ENGINEERING ASSOCIATES, § INC., § DEFENDANT. § DALLAS COUNTY, TEXAS THIRD-PARTY DEFENDANT BK CORROSION LLC’S UNOPPOSED FIRST MOTION FOR CONTINUANCE TO THE HONORABLE JUDGE OF SAID COURT: Third-Party Defendant BK Corrosion, LLC files this its Unopposed First Motion for Continuance, and as grounds therefore would show the Court the following: I. This case is set for trial on March 7, 2023. This is the first trial setting. This is the first Motion for Continuance. Counsel for Plaintiff and Counsel for Defendant do not oppose this Motion. II. This case was originally filed on December 6, 2021. Defendant Elk Engineering Associates, Inc. filed its Answer on February 14, 2022. On December 1, 2022, Defendant filed its Third-Party Petition. Third-Party Defendant BK Corrosion, LLC has timely filed its Answer to Third-Party Petition on January 20, 2023, the date of the filing of this Motion. This Third-Party Defendant needs time to conduct discovery in this case in order to defend itself and determine the allegations against it. Therefore, a continuance of the trial setting for sufficient time for this party to prepare for trial is requested. This party requests a continuance of no less than 180 days. This Motion is not made for solely for the purpose of delay but rather that justice be done. THIRD-PARTY DEFENDANT’S MOTION FOR CONTlNUAN CE l WI-IEREFORE, PREMISES CONSIDERED, Third-Party Defendant BK Corrosion, LLC prays that the Court continue this cause from its present trial setting of March 7, 2023 to some later term of Court to be determined by the Court and to such and other and further relief at law or in equity. Respectfully Submitted, .AYIK & ASSOCIATES /s/ Shelly S. Jock SHELLY S. JOCK Texas Bar No. 00794026 E-Mail: sjock@travelers.com Mailing Address: P.O. Box 64093 St. Paul, MN 55164-0093 Physical Address 1301 E. Collins Blvd, Suite 290 Richardson, Texas 75081 Direct Telephone: 214-200-2292 Main Telephone: 214-570-6300 ATTORNEYS FOR THIRD-PARTY DEFENDANT BK CORROSION, LLC THIRD-PARTY DEFENDANT’S MOTION FOR CONTlNUAN CE DECLARATION OF SHELLY S. JOCK I, Shelly S. Jock, have personal knowledge of facts stated herein and certify that they are true and correct to best of my knowledge. /s/ Shell S. Jock SHELLY SJOCK CERTIFICATE OF CONFERENCE Third-Party Defendant's counsel has conferred with the attorneys in this cause and agreement has been reached, and therefore it is requested that this matter be granted. /s/ Shelly S. Jock Shelly S. Jock CERTIFICATE OF SERVICE This is to certify that, on this the 20th day of January, 2023, a true and correct copy of the foregoing document was forwarded to all counsel of record as follows Via eservice. Curtis Hubbard Hand Delivery Nixon Jach Hubbard, PLLC Facsimile 14241 Dallas Parkway, Suite 575 Certified Mail, Return Receipt Requested Dallas, TX 75245 Receipted Commercial Delivery Facsimile 972-503- 7001 Regular U.S. Mail Attorney for Plaintiflf x E-service Reyes Group, Ltd Angela D. Caffey Hand Delivery Thompson, Coe, Cousins & Irons, LLP Facsimile 700 N. Pearl Street, 25th Floor Certified Mail, Return Receipt Requested Dallas, TX 75201 Receipted Commercial Delivery Attorney for Defendant, Elk Engineering Regular U.S. Mail Associates, Inc. x E-service /s/ Shelly S. Jock Shelly S. Jock THIRD-PARTY DEFENDANT’S MOTION FOR CONTlNUAN CE 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. Donna Pitek on behalf of Shelly Jock Bar No. 794026 dpitek@travelers.com Envelope ID: 71982407 Status as of 1/20/2023 12:13 PM CST Associated Case Party: ELK ENGINEERING ASSOCIATES, INC. Name BarNumber Email TimestampSubmitted Status Daniel PBuechler dbuechler@thompsoncoe.com 1/20/2023 11:38:11 AM SENT Angela DCaffey acaffey@thompsoncoe.com 1/20/2023 11:38:11 AM SENT Lindsey Robison Irobison@thompsoncoe.com 1/20/2023 11:38:11 AM SENT Susan Dyess sdyess@thompsoncoe.com 1/20/2023 11:38:11 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Cathy Schmitz cschmitz@thompsoncoe.com 1/20/2023 11:38:11 AM SENT 101st District Court 101court@dallascounty.org 1/20/2023 11:38:11 AM SENT Laura Deen |deen@njh-Iaw.com 1/20/2023 11:38:11 AM SENT CURTIS HUBBARD chubbard@njh-law.com 1/20/2023 11:38:11 AM SENT Associated Case Party: BK Corrosion, LLC Name BarNumber Email Timestam pSubmitted Status Shelly S.Jock sjock@travelers.com 1/20/2023 11:38:11 AM SENT