On February 25, 2021 a
Stipulation,Agreement
was filed
involving a dispute between
Nguyen, Phuong Thi Cam,
and
Ashagre, Ruth Samson,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
7/6/2021 6:00 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
CAUSE N0. DC-21-02470 Cassandra Walker DEPUTY
PHOUNG NGUYEN, § IN THE DISTRICT COURT
§
Plaintlffi §
§
V. § IOIST JUDICIAL DISTRICT
§
RUTH SAMSON ASHAGRE, §
§
Defendant. § DALLAS COUNTY, TEXAS
AGREED MOTION TO LIFT AUTOMATIC STAY
COME NOW Defendant Ruth Samson Ashagre and Plaintiff Phoung Nguyen, filing this
Agreed Motion to Lift the Automatic Stay and reinstate this lawsuit to the Court’s active docket,
as follows:
1. Defendant’s insurance carrier, ACCC Insurance Company (“ACCC”), was
declared insolvent by the Texas Commissioner of Insurance on December 14, 2020. As such, this
lawsuit is subject to the Texas Property and Casualty Insurance Guaranty Act, 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 March 17, 2021.
2. The statutory stay period has now expired, and the parties wish for this matter to be
reinstated to the Court’s active docket.
WHEREFORE, Defendant prays the Court grant this Motion to Lift Automatic Stay,
reinstate this case to the Court’s active docket, and set this matter for trial.
Agreed Motion to LiftAutomatic Stay (145. 0088) Page I of2
Respectfully submitted,
THE WILLIS LAW GROUP, PLLC
/s/ Matthew B. Savegh
ADAM C. GALLEGOS
State Bar No. 24036614
MATTHEW B. SAYEGH
State Bar No. 24104359
KIRK D. WILLIS
State Bar N0. 21648500
1985 Forest Lane
Garland, Texas 75042
Telephone: (214) 736-9433
Facsimile: (214) 73 6-9994
service@thewillislawgroup.com
ATTORNEYS FOR DEFENDANT
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing document
has been forwarded to all counsel of record Via E-Service on the 2nd day of July, 2021.
/s/M¢_ltthew B. Swh
MATTHEW B. SAYEGH
CERTIFICATE 0F CONFERENCE
On June 29, 2021, the undersigned attorney spoke with Bich Tran, counsel for Plaintiff, to
discuss the foregoing motion. Counsel indicated she is in agreement with the relief sought herein,
which is presented to the Court for entry.
/s/ Matthew B. Savegh
MATTHEW B. SAYEGH
Agreed Motion to Lift Automatic Stay (145. 0088) Page 2 of 2
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.
Candace Moore on behalf of Matthew Sayegh
Bar No. 24104359
cmoore@thewillislawgroup.com
Envelope ID: 55089510
Status as of 7/8/2021 11:17 AM CST
Associated Case Party: PHUONGTHI CAMNGUYEN
Name BarNumber Email TimestampSubmitted Status
Ngoc-Bich Tran 2401 1459 btran@btranlaw.legal 7/6/2021 6:00:53 PM SENT
Associated Case Party: RUTHSAMSONASHAGRE
Name BarNumber Email TimestampSubmitted Status
Matthew B.Sa|inas service@thewillislawgroup.com 7/6/2021 6:00:53 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Adam C.Gallegos service@thewillislawgroup.com 7/6/2021 6:00:53 PM SENT
Document Filed Date
July 06, 2021
Case Filing Date
February 25, 2021
Category
MOTOR VEHICLE ACCIDENT
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FILED 7/6/2021 6:00 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS CAUSE N0. DC-21-02470 Cassandra Walker DEPUTY PHOUNG NGUYEN, § IN THE DISTRICT COURT § Plaintlffi § § V. § IOIST JUDICIAL DISTRICT § RUTH SAMSON ASHAGRE, § § Defendant. § DALLAS COUNTY, TEXAS AGREED MOTION TO LIFT AUTOMATIC STAY COME NOW Defendant Ruth Samson Ashagre and Plaintiff Phoung Nguyen, filing this Agreed Motion to Lift the Automatic Stay and reinstate this lawsuit to the Court’s active docket, as follows: 1. Defendant’s insurance carrier, ACCC Insurance Company (“ACCC”), was declared insolvent by the Texas Commissioner of Insurance on December 14, 2020. As such, this lawsuit is subject to the Texas Property and Casualty Insurance Guaranty Act, 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 March 17, 2021. 2. The statutory stay period has now expired, and the parties wish for this matter to be reinstated to the Court’s active docket. WHEREFORE, Defendant prays the Court grant this Motion to Lift Automatic Stay, reinstate this case to the Court’s active docket, and set this matter for trial. Agreed Motion to LiftAutomatic Stay (145. 0088) Page I of2 Respectfully submitted, THE WILLIS LAW GROUP, PLLC /s/ Matthew B. Savegh ADAM C. GALLEGOS State Bar No. 24036614 MATTHEW B. SAYEGH State Bar No. 24104359 KIRK D. WILLIS State Bar N0. 21648500 1985 Forest Lane Garland, Texas 75042 Telephone: (214) 736-9433 Facsimile: (214) 73 6-9994 service@thewillislawgroup.com ATTORNEYS FOR DEFENDANT CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing document has been forwarded to all counsel of record Via E-Service on the 2nd day of July, 2021. /s/M¢_ltthew B. Swh MATTHEW B. SAYEGH CERTIFICATE 0F CONFERENCE On June 29, 2021, the undersigned attorney spoke with Bich Tran, counsel for Plaintiff, to discuss the foregoing motion. Counsel indicated she is in agreement with the relief sought herein, which is presented to the Court for entry. /s/ Matthew B. Savegh MATTHEW B. SAYEGH Agreed Motion to Lift Automatic Stay (145. 0088) Page 2 of 2 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. Candace Moore on behalf of Matthew Sayegh Bar No. 24104359 cmoore@thewillislawgroup.com Envelope ID: 55089510 Status as of 7/8/2021 11:17 AM CST Associated Case Party: PHUONGTHI CAMNGUYEN Name BarNumber Email TimestampSubmitted Status Ngoc-Bich Tran 2401 1459 btran@btranlaw.legal 7/6/2021 6:00:53 PM SENT Associated Case Party: RUTHSAMSONASHAGRE Name BarNumber Email TimestampSubmitted Status Matthew B.Sa|inas service@thewillislawgroup.com 7/6/2021 6:00:53 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Adam C.Gallegos service@thewillislawgroup.com 7/6/2021 6:00:53 PM SENT