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FILED
9/17/2021 1:48 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
CAROLYN SELLERS DEPUTY
CAUSE NO. DC-21-11378
ERIC WILSON, INDIVIDUALLY, AND IN THE DISTRICT COURT
AS NEXT FRIEND OF MINORS J .C.,
A.W., Z.C. AND Z.C., PLAINTIFFS
116TH DISTRICT COURT
V.
ALLSTATE FIRE AND CASUALTY DALLAS COUNTY TEXAS
INSURANCE COMPANY,
DEFENDANT
MOTION FOR APPOINTMENT OF GUARDIAN AD LITEM
TO THE HONORABLE JUDGE OF SAID COURT:
In accordance with TRCP 173.2 comes now ERIC WILSON, INDIVIDUALLY, AND AS
NEXT FRIEND OF AIDEN WILSON, JADEN CALDWELL, ZADEN CALDWELL, AND
ZAYLEN CALDWELL, HEREINAFTER KNOWN AS A.W., J.C., Z.C. AND Z.C., Minor
Plaintiffs, complaining of ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY,
DEFENDANT, and move this Honorable Court for the appointment of a Guardian Ad Litem, to
represent the interest of PLAINTIFFS J .C., A.W., Z.C., and Z.C., and in support thereof would
respectfully show the Court as follows:
I.
Parties would further show the Court that .C., A.W., Z.C.J AND Z.C. are minors whose
interest would be best represented in this action by a Guardian Ad Litem.
II.
The above parties agree to the appointment of MARIFER ACEVES as a Guardian Ad
Litem, and believe that she will properly represent the best interests of the minor.
WHEREFORE, PREMISES CONSIDERED, Plaintiffs and Defendant pray that this
Motion be set for a hearing, if necessary, and that after consideration thereof, the Court grant this
Motion and appoint a Guardian Ad Litem to represent the interest of the minor Plaintiffs, A.W.,
Minor Settlement: Wilson, et a1. v. Allstate PAGE 1
MOTION FOR APPOINTMENT OF GUARDIAN AD LITEM
Our File Number: 05677382401
J .C., Z.C. AND Z.C., and for such other and further relief to which they show themselves to be
justly entitled.
Respectfully submitted,
GODSEY MARTIN LAW FIRM*
/s/ Susan B. Smith
(with permission)
SUSAN B. SMITH
TBN: 15943610
15000 Surveyor Blvd.
Addison, TX 75001
(214) 744-3339
(972) 301-2444 (fax)
ATTORNEY FOR PLAINTIFFS,
ERIC CALDWELL, INDIVIDUALLY,
AND AS NEXT FRIEND OF MINORS
J.C., A.W., Z.C. AND Z.C.,
LISA CHASTAIN & ASSOCIATES
M194
mg
KATE GARDNER
TBN: 24101788
1201 Elm Street, Suite 5050
Dallas, TX 75270
E-Service Only: DallasLegal@allstate.com
(214) 676-8026
(877) 67 8-4763 (fax)
ATTORNEY FOR DEFENDANT,
ALLSTATE FIRE AND CASUALTY
INSURANCE COMPANY
Minor Settlement: Wilson, et a1. v. Allstate PAGE 2
MOTION FOR APPOINTMENT OF GUARDIAN AD LITEM
Our File Number: 05677382401
CERTIFICATE 0F CONFERENCE
A conference was held on 9-17-21 with Susan B. Smith, attorney for Plaintiffs regarding
this Motion. Parties are agreed as to chosen Guardian Ad Litem, Marifer Aceves.
WML
KATE GARDNER
Minor Settlement: Wilson, et a1. v. Allstate PAGE 3
MOTION FOR APPOINTMENT OF GUARDIAN AD LITEM
Our File Number: 05677382401
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.
Envelope ID: 57363644
Status as of 9/20/2021 3:54 PM CST
Associated Case Party: ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY
Name BarNumber Email TimestampSubmitted Status
Kate Gardner DallasLegal@allstate.com 9/17/2021 1:48:37 PM SENT
Associated Case Party: ERIC WILSON
Name BarNumber Email TimestampSubmitted Status
Susan B.Smith gmlit@gmfirm.com 9/17/2021 1:48:37 PM SENT
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FILED 9/17/2021 1:48 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS CAROLYN SELLERS DEPUTY CAUSE NO. DC-21-11378 ERIC WILSON, INDIVIDUALLY, AND IN THE DISTRICT COURT AS NEXT FRIEND OF MINORS J .C., A.W., Z.C. AND Z.C., PLAINTIFFS 116TH DISTRICT COURT V. ALLSTATE FIRE AND CASUALTY DALLAS COUNTY TEXAS INSURANCE COMPANY, DEFENDANT MOTION FOR APPOINTMENT OF GUARDIAN AD LITEM TO THE HONORABLE JUDGE OF SAID COURT: In accordance with TRCP 173.2 comes now ERIC WILSON, INDIVIDUALLY, AND AS NEXT FRIEND OF AIDEN WILSON, JADEN CALDWELL, ZADEN CALDWELL, AND ZAYLEN CALDWELL, HEREINAFTER KNOWN AS A.W., J.C., Z.C. AND Z.C., Minor Plaintiffs, complaining of ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY, DEFENDANT, and move this Honorable Court for the appointment of a Guardian Ad Litem, to represent the interest of PLAINTIFFS J .C., A.W., Z.C., and Z.C., and in support thereof would respectfully show the Court as follows: I. Parties would further show the Court that .C., A.W., Z.C.J AND Z.C. are minors whose interest would be best represented in this action by a Guardian Ad Litem. II. The above parties agree to the appointment of MARIFER ACEVES as a Guardian Ad Litem, and believe that she will properly represent the best interests of the minor. WHEREFORE, PREMISES CONSIDERED, Plaintiffs and Defendant pray that this Motion be set for a hearing, if necessary, and that after consideration thereof, the Court grant this Motion and appoint a Guardian Ad Litem to represent the interest of the minor Plaintiffs, A.W., Minor Settlement: Wilson, et a1. v. Allstate PAGE 1 MOTION FOR APPOINTMENT OF GUARDIAN AD LITEM Our File Number: 05677382401 J .C., Z.C. AND Z.C., and for such other and further relief to which they show themselves to be justly entitled. Respectfully submitted, GODSEY MARTIN LAW FIRM* /s/ Susan B. Smith (with permission) SUSAN B. SMITH TBN: 15943610 15000 Surveyor Blvd. Addison, TX 75001 (214) 744-3339 (972) 301-2444 (fax) ATTORNEY FOR PLAINTIFFS, ERIC CALDWELL, INDIVIDUALLY, AND AS NEXT FRIEND OF MINORS J.C., A.W., Z.C. AND Z.C., LISA CHASTAIN & ASSOCIATES M194 mg KATE GARDNER TBN: 24101788 1201 Elm Street, Suite 5050 Dallas, TX 75270 E-Service Only: DallasLegal@allstate.com (214) 676-8026 (877) 67 8-4763 (fax) ATTORNEY FOR DEFENDANT, ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY Minor Settlement: Wilson, et a1. v. Allstate PAGE 2 MOTION FOR APPOINTMENT OF GUARDIAN AD LITEM Our File Number: 05677382401 CERTIFICATE 0F CONFERENCE A conference was held on 9-17-21 with Susan B. Smith, attorney for Plaintiffs regarding this Motion. Parties are agreed as to chosen Guardian Ad Litem, Marifer Aceves. WML KATE GARDNER Minor Settlement: Wilson, et a1. v. Allstate PAGE 3 MOTION FOR APPOINTMENT OF GUARDIAN AD LITEM Our File Number: 05677382401 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. Envelope ID: 57363644 Status as of 9/20/2021 3:54 PM CST Associated Case Party: ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY Name BarNumber Email TimestampSubmitted Status Kate Gardner DallasLegal@allstate.com 9/17/2021 1:48:37 PM SENT Associated Case Party: ERIC WILSON Name BarNumber Email TimestampSubmitted Status Susan B.Smith gmlit@gmfirm.com 9/17/2021 1:48:37 PM SENT