On January 30, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Aaa Texas County Mut. Ins. Co.,
and
Santos, Juan Manuel,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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FILED
3/21/2023 3:37 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Jeremy Jones DEPUTY
Cause No. DC-23—01471
AAA TEXAS COUNTY MUT. INS. C0. § IN THE DISTRICT COURT
é
V. § DALLAS COUNTY, TEXAS
é
JUAN MANUEL SANTOS § IOIST JUDICIAL DISTRICT
PLAINTIFF’S VERIFIED MOTION TO RETAIN CAUSE
COMES NOW Plaintiff, AAA TEXAS COUNTY MUT. INS. CO., and files this
Verified Motion to Retain the above referenced cause and in support of same would show as
follows:
Introduction
l. On January 30, 2023, Plaintiff filed this lawsuit.
2. On February 10, 2023, Plaintiff sent the citation out for service via private process server.
3. On February 28, 2023. Plaintiff received correspondence from the server stating a vehicle
parked at 6903 Thornwood Dr., Dallas, TX 75227 is registered to Defendant.
4. On March 1, 2023, Plaintiff requested a non-service affidavit in support of a Motion for
Substitute Service.
5. On March 15, 2023, Plaintifi followed up with the non-service affidavit and was
informed the property at 6903 Thomwood Dr., Dallas, TX 75227 is registered to Defendant Juan
Manuel Santos.
6 On March I6, 2023, Plaintiff filed a Motion for Substitute Service.
G006 C3US6
7. Plaintifi does intend to complete service for Defendant Juan Manuel Santos.
8. Plaintifi‘ respectfully requests that the Court retain this cause and, subject to completion
of service.
9. The verification of Plaintiff’s counsel, Jason E. Wells is attached.
Prayer
10. Wherefore, premises considered Plaintiff respectfully prays the Court to retain this cause,
and subject to completion of service.
Respectfully submitted,
THE FUSSELMAN LAW FIRM, P.C.
/s/ Jason E. Wells
Christopher A. Fussehnan
State Bar No. 00792520
Jason E. Wells
State Bar No. 24066279
1616 South Voss Rd., Ste. 775
Houston, Texas 77057
(713) 960-1619
(713) 960-1430 (fax)
E-Service E—Mail:
e-file@thefusselmanlawfirm.com
ATTORNEYS FOR PLAINTIFF
Cause No. 13023-01471
AAA TEXAS COUNTY MUT. INS. CO. § IN THE DISTRICT COURT
§
§
V. § DALLAS COUNTY, TEXAS
é
JUAN MANUEL SANTOS § 1'01ST JUDICIAL DISTRICT
VERIFICATION OF PLAINTIFF’S COUNSEL
STATE OF TEXAS §
§
HARRIS COUNTY §
Before me the undersigned notary, on this day personally appeared Jason B. Wells, a person
Whose identity is known to me. After I administered an oath to him, upon his oath he said he read
Plaintiff’s Verified Motion to Retain Cause, and that all other facts stated in it are Within his
personal knowledge and are true and correct.
Jaso . Wells
SUBSCRIBED AND SWORN TO BEFORE ME on this the 21St day of March, 2023.
SZ WWW/V
NOTAK’Y PUB’LIC, STATE OF TEXAS
ZAYURY TORRES
Notary 30 #133817253
My Commission Expires
Ga June 16, 2026
Document Filed Date
March 21, 2023
Case Filing Date
January 30, 2023
Category
MOTOR VEHICLE ACCIDENT
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FILED 3/21/2023 3:37 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Jeremy Jones DEPUTY Cause No. DC-23—01471 AAA TEXAS COUNTY MUT. INS. C0. § IN THE DISTRICT COURT é V. § DALLAS COUNTY, TEXAS é JUAN MANUEL SANTOS § IOIST JUDICIAL DISTRICT PLAINTIFF’S VERIFIED MOTION TO RETAIN CAUSE COMES NOW Plaintiff, AAA TEXAS COUNTY MUT. INS. CO., and files this Verified Motion to Retain the above referenced cause and in support of same would show as follows: Introduction l. On January 30, 2023, Plaintiff filed this lawsuit. 2. On February 10, 2023, Plaintiff sent the citation out for service via private process server. 3. On February 28, 2023. Plaintiff received correspondence from the server stating a vehicle parked at 6903 Thornwood Dr., Dallas, TX 75227 is registered to Defendant. 4. On March 1, 2023, Plaintiff requested a non-service affidavit in support of a Motion for Substitute Service. 5. On March 15, 2023, Plaintifi followed up with the non-service affidavit and was informed the property at 6903 Thomwood Dr., Dallas, TX 75227 is registered to Defendant Juan Manuel Santos. 6 On March I6, 2023, Plaintiff filed a Motion for Substitute Service. G006 C3US6 7. Plaintifi does intend to complete service for Defendant Juan Manuel Santos. 8. Plaintifi‘ respectfully requests that the Court retain this cause and, subject to completion of service. 9. The verification of Plaintiff’s counsel, Jason E. Wells is attached. Prayer 10. Wherefore, premises considered Plaintiff respectfully prays the Court to retain this cause, and subject to completion of service. Respectfully submitted, THE FUSSELMAN LAW FIRM, P.C. /s/ Jason E. Wells Christopher A. Fussehnan State Bar No. 00792520 Jason E. Wells State Bar No. 24066279 1616 South Voss Rd., Ste. 775 Houston, Texas 77057 (713) 960-1619 (713) 960-1430 (fax) E-Service E—Mail: e-file@thefusselmanlawfirm.com ATTORNEYS FOR PLAINTIFF Cause No. 13023-01471 AAA TEXAS COUNTY MUT. INS. CO. § IN THE DISTRICT COURT § § V. § DALLAS COUNTY, TEXAS é JUAN MANUEL SANTOS § 1'01ST JUDICIAL DISTRICT VERIFICATION OF PLAINTIFF’S COUNSEL STATE OF TEXAS § § HARRIS COUNTY § Before me the undersigned notary, on this day personally appeared Jason B. Wells, a person Whose identity is known to me. After I administered an oath to him, upon his oath he said he read Plaintiff’s Verified Motion to Retain Cause, and that all other facts stated in it are Within his personal knowledge and are true and correct. Jaso . Wells SUBSCRIBED AND SWORN TO BEFORE ME on this the 21St day of March, 2023. SZ WWW/V NOTAK’Y PUB’LIC, STATE OF TEXAS ZAYURY TORRES Notary 30 #133817253 My Commission Expires Ga June 16, 2026