On May 31, 2023 a
PLAINITFF MTN RETAIN - MOTION - RETAIN
was filed
involving a dispute between
At&T Services, Inc.,
and
Hall, Mason, Iii,
Nobles, Willie Mae,
for OTHER PERSONAL INJURY
in the District Court of Dallas County.
Preview
FILED
7/17/2023 2:30 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Margaret Thomas DEPUTY
Cause No. DC—23-07279
AT&T SERVICES, INC. § IN THE DISTRICT COURT
§
V. §
§ 193RD JUDICIAL DISTRICT
§
MASON HALL III AND §
WILLIE MAE NOBLBS § DALLASCOUNTY, TEXAS
PLAINTIFF’S VERIFIED MOTION TO RETAIN CAUSE
COMES NOW Plaintiff, AT&T SERVICES, INC., and files this Verified Motion to
Retain the above referenced cause and in support of same would show as follows:
lam—(WM
1. On May 31, 2023, Plaintiff filed this lawsuit.
2. On June 26, 2023, Plaintiff followed up with the citations and was told the citations were
issued June 5, 2023. Plaintiff informed the clerk, e—file had blacklisted Plaintiff’ s service e—mail
in Dallas County for reasons unknown to Plaintiff. A ticket was opened with the e-file support
team to resolve the issue. The clerk stated she would have Ms. Madeline resend the citations to
the e—service email on file.
3. On June 28, 2023, Plaintiff downloaded the citations from the clerk’s website.
4. On June 30, 2023, Plaintiff sent the citations out for service via private process server.
5. On July 6, 2023, Plaintiff followed up with service and was told service had not yet been
completed; however, service attempts were continuing.
6. On July l7, 2023, Plaintiff followed up with server via phone and was told on July 12,
there was no answer at the door. On July 14, 2023, Defendant Willie Mae Nobles was served, the
server was then informed that Defendant Mason Hall III was not home at the time. Plaintiff is
currently waiting for the Affidavit of Service for Willie Mae Nobles. Service attempts for
Defendant Mason Hall 111 are continuing.
Good Cause
7. Plaintiff does intend to complete service for Mason Hall III. Plaintiff intends to allow the
proper time for Defendant Willie Mae Nobles to file an answer with the Court.
8. Plaintiff respectfully requests that the Court retain this cause and, subject to completion
of service of Defendant Mason Hall III and the expiration of Defendant Willie Mae Nobles’
deadline to filean answer with the Court.
9. The verification of Plaintiff’s counsel, Christopher A. Fusselman is attached.
Prayer
10. Wherefore, premises considered Plaintiff respectfully prays the Court to retain this cause,
and subject to completion of service for Defendant Mason Hall 111 and the expiration of
Defendant Willie Mae Nobles’ deadline to file an answer with the Court.
Respectfiilly submitted,
THE FUSSELMAN LAW FIRM, P.C.
/s/ Christotoher A. Fusselman
Christopher A. Fusselman
State Bar No. 00792520
Jason B. 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.c0m
ATTORNEYS FOR PLAINTIFF
Cause No. DC-23-07279
AT&T SERVICES, INC. § IN THE DISTRICT COURT
§
V. §
§ 193RD JUDICIAL DISTRICT
§
MASON HALL III AND §
WILLIE MAE NOBLES § DALLASCOUNTY, TEXAS
VERIFICATION OF PLAINTIFF ’S COUNSEL
STATE OF TEXAS §
, §
HARRIS COUNTY §
Before me the undersigned notary, on this day personally appeared Christopher A.
Fusselman, a person whose identity is known to me. After I administered an oath to him, upon his
oath he said he read Plaintiffs Verified Motion to Retain Cau d that all other facts stated in
it are within his personal knowledge and are true and
'stOphJr A. Fusselman
SUBSCRIBED AND SWORN TO BEFORE ME on this the 17th day of July, 2023.
g’lfiYW PUBLIC, STATE OF TEXAS
IAYURY TORRES
Notary ID #133817253
My Commission Expires
{Po June 16, 2026
Document Filed Date
July 17, 2023
Case Filing Date
May 31, 2023
Category
OTHER PERSONAL INJURY
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED 7/17/2023 2:30 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Margaret Thomas DEPUTY Cause No. DC—23-07279 AT&T SERVICES, INC. § IN THE DISTRICT COURT § V. § § 193RD JUDICIAL DISTRICT § MASON HALL III AND § WILLIE MAE NOBLBS § DALLASCOUNTY, TEXAS PLAINTIFF’S VERIFIED MOTION TO RETAIN CAUSE COMES NOW Plaintiff, AT&T SERVICES, INC., and files this Verified Motion to Retain the above referenced cause and in support of same would show as follows: lam—(WM 1. On May 31, 2023, Plaintiff filed this lawsuit. 2. On June 26, 2023, Plaintiff followed up with the citations and was told the citations were issued June 5, 2023. Plaintiff informed the clerk, e—file had blacklisted Plaintiff’ s service e—mail in Dallas County for reasons unknown to Plaintiff. A ticket was opened with the e-file support team to resolve the issue. The clerk stated she would have Ms. Madeline resend the citations to the e—service email on file. 3. On June 28, 2023, Plaintiff downloaded the citations from the clerk’s website. 4. On June 30, 2023, Plaintiff sent the citations out for service via private process server. 5. On July 6, 2023, Plaintiff followed up with service and was told service had not yet been completed; however, service attempts were continuing. 6. On July l7, 2023, Plaintiff followed up with server via phone and was told on July 12, there was no answer at the door. On July 14, 2023, Defendant Willie Mae Nobles was served, the server was then informed that Defendant Mason Hall III was not home at the time. Plaintiff is currently waiting for the Affidavit of Service for Willie Mae Nobles. Service attempts for Defendant Mason Hall 111 are continuing. Good Cause 7. Plaintiff does intend to complete service for Mason Hall III. Plaintiff intends to allow the proper time for Defendant Willie Mae Nobles to file an answer with the Court. 8. Plaintiff respectfully requests that the Court retain this cause and, subject to completion of service of Defendant Mason Hall III and the expiration of Defendant Willie Mae Nobles’ deadline to filean answer with the Court. 9. The verification of Plaintiff’s counsel, Christopher A. Fusselman is attached. Prayer 10. Wherefore, premises considered Plaintiff respectfully prays the Court to retain this cause, and subject to completion of service for Defendant Mason Hall 111 and the expiration of Defendant Willie Mae Nobles’ deadline to file an answer with the Court. Respectfiilly submitted, THE FUSSELMAN LAW FIRM, P.C. /s/ Christotoher A. Fusselman Christopher A. Fusselman State Bar No. 00792520 Jason B. 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.c0m ATTORNEYS FOR PLAINTIFF Cause No. DC-23-07279 AT&T SERVICES, INC. § IN THE DISTRICT COURT § V. § § 193RD JUDICIAL DISTRICT § MASON HALL III AND § WILLIE MAE NOBLES § DALLASCOUNTY, TEXAS VERIFICATION OF PLAINTIFF ’S COUNSEL STATE OF TEXAS § , § HARRIS COUNTY § Before me the undersigned notary, on this day personally appeared Christopher A. Fusselman, a person whose identity is known to me. After I administered an oath to him, upon his oath he said he read Plaintiffs Verified Motion to Retain Cau d that all other facts stated in it are within his personal knowledge and are true and 'stOphJr A. Fusselman SUBSCRIBED AND SWORN TO BEFORE ME on this the 17th day of July, 2023. g’lfiYW PUBLIC, STATE OF TEXAS IAYURY TORRES Notary ID #133817253 My Commission Expires {Po June 16, 2026