On July 26, 2021 a
Stipulation,Agreement
was filed
involving a dispute between
Weldon Contractors, Llc D B A Weldon Contractors,
and
Czot Mgs Llc,
Hartford Fire Insurance Company,
for OTHER CONTRACT
in the District Court of Dallas County.
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FILED
9/23/2022 9:07 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Kevin Molden DEPUTY
CAUSE NO. DC-21-09687
WELDON CONTRACTORS, LLC § IN THE DISTRICT COURT OF
D / B / A WELDON CONTRACTORS §
§
Plaintiff, §
§
V. § 193ml IUDICIAL DISTRICT
§
CZOT / MGS LLC AND HARTFORD §
FIRE INSURANCE COMPANY §
§
Defendants. § DALLAS COUNTY, TEXAS
AGREED MOTION FOR CONTINUANCE
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Plaintiff Weldon Contractors, LLC d/b/ a Weldon Contractors
("Weldon”) and Defendants CZOT / MGS LLC ("Construction Zone”) and Hartford Fire
Insurance Company (”Hartford”) (collectively ”Parties”) and files this Agreed Motion
for Continuance, and in support hereof show the Court the following:
I. BACKGROUND &: FACTS
This case was filed on July 26, 2021 for the recovery of unpaid amounts owed to
Weldon by Construction Zone and is set for a jury trial on October 11, 2022.
Parties have agreed to this continuance as evidenced by the signatures below.
II. MOTION FOR CONTINUANCE
Parties agree that the trial of this matter be continued until at least the week of
February 20, 2023 to give all parties a chance to settle or mediate this case and conduct
necessary discovery, primarily depositions of fact and expert witnesses, to properly
prepare for trial. Parties will endeavor to submit an agreed scheduling order reflecting
the requested trial setting.
AGREED MOTION FOR CONTINUANCE PAGE 1
No prejudice will result to the Parties as a result of the requested continuance.
Pursuant to Tex. R. Civ. P. 251, courts may grant continuances when the parties have
consented. This continuance is not sought for delay only, but that justice may be done.
WHEREFORE, PREMISES CONSIDERED, Movants request the Court to grant this
Motion for Continuance, and to continue the trial setting until at least the week of
February 20, 2023, and for such other and further relief that may be awarded at law or in
equity.
Respectfully submitted,
THOMAS, FELDMAN 8: WILSHUSEN, L.L.P.
By: /s/ Michael T. Pipkz’n
TODD R. NECTOUX
State Bar No. 24032899
Email: tnectoux@tfandw.com
MICHAEL T. PIPKIN
State Bar No. 24122988
Email: mpipkin@tfandw.com
Merit Tower
12222 Merit Drive, Suite 1450
Dallas, Texas 75251
Telephone: (214) 369-3008
Telecopier: (214) 369-8393
ATTORNEYS FOR WELDON
CONTRACTORS, LLC D/B/A
WELDON CONTRACTORS
AGREED:
[sz Charlie Conway with permission September 22, 2023 [sZ Michael Pipkin
Charlie Conway
Attorney for CZOT/MGS
LLC and Hartford Fire
Insurance Company
AGREED MOTION FOR CONTINUANCE PAGE 2
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the above and foregoing document
has been forwarded to all counsel of record on the 23rd day of September 2022, in
accordance with Rule 21a of the Texas Rules of Civil Procedure.
VIA E-FILE
Charlie Conway
WT SKIP LEAKE, PC.
350 Westpark Way, Ste. 205
Euless, Texas 76040
[Si Michael T. Pipkz'n
Michael T. Pipkin
AGREED MOTION FOR CONTINUANCE PAGE 3
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.
Mario Young on behalf of Michael Pipkin
Bar No. 24122988
myoung@tfandw.com
Envelope ID: 68545510
Status as of 9/23/2022 2:13 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Todd R.Nectoux tnectoux@tfandw.com 9/23/2022 9:07:03 AM SENT
W T Skip Leake skip@leakelaw.com 9/23/2022 9:07:03 AM SENT
Jonathan C.Conway cconway@leakelaw.com 9/23/2022 9:07:03 AM SENT
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.
Mario Young on behalf of Michael Pipkin
Bar No. 24122988
myoung@tfandw.com
Envelope ID: 68545510
Status as of 9/23/2022 2:13 PM CST
Associated Case Party: HARTFORD FIRE INSURANCE COMPANY
Name BarNumber Email TimestampSubmitted Status
Maribel Luzunaris Maribel.Luzunaris@thehartford.com 9/23/2022 9:07:03 AM SENT
Document Filed Date
September 23, 2022
Case Filing Date
July 26, 2021
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FILED 9/23/2022 9:07 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Kevin Molden DEPUTY CAUSE NO. DC-21-09687 WELDON CONTRACTORS, LLC § IN THE DISTRICT COURT OF D / B / A WELDON CONTRACTORS § § Plaintiff, § § V. § 193ml IUDICIAL DISTRICT § CZOT / MGS LLC AND HARTFORD § FIRE INSURANCE COMPANY § § Defendants. § DALLAS COUNTY, TEXAS AGREED MOTION FOR CONTINUANCE TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Plaintiff Weldon Contractors, LLC d/b/ a Weldon Contractors ("Weldon”) and Defendants CZOT / MGS LLC ("Construction Zone”) and Hartford Fire Insurance Company (”Hartford”) (collectively ”Parties”) and files this Agreed Motion for Continuance, and in support hereof show the Court the following: I. BACKGROUND &: FACTS This case was filed on July 26, 2021 for the recovery of unpaid amounts owed to Weldon by Construction Zone and is set for a jury trial on October 11, 2022. Parties have agreed to this continuance as evidenced by the signatures below. II. MOTION FOR CONTINUANCE Parties agree that the trial of this matter be continued until at least the week of February 20, 2023 to give all parties a chance to settle or mediate this case and conduct necessary discovery, primarily depositions of fact and expert witnesses, to properly prepare for trial. Parties will endeavor to submit an agreed scheduling order reflecting the requested trial setting. AGREED MOTION FOR CONTINUANCE PAGE 1 No prejudice will result to the Parties as a result of the requested continuance. Pursuant to Tex. R. Civ. P. 251, courts may grant continuances when the parties have consented. This continuance is not sought for delay only, but that justice may be done. WHEREFORE, PREMISES CONSIDERED, Movants request the Court to grant this Motion for Continuance, and to continue the trial setting until at least the week of February 20, 2023, and for such other and further relief that may be awarded at law or in equity. Respectfully submitted, THOMAS, FELDMAN 8: WILSHUSEN, L.L.P. By: /s/ Michael T. Pipkz’n TODD R. NECTOUX State Bar No. 24032899 Email: tnectoux@tfandw.com MICHAEL T. PIPKIN State Bar No. 24122988 Email: mpipkin@tfandw.com Merit Tower 12222 Merit Drive, Suite 1450 Dallas, Texas 75251 Telephone: (214) 369-3008 Telecopier: (214) 369-8393 ATTORNEYS FOR WELDON CONTRACTORS, LLC D/B/A WELDON CONTRACTORS AGREED: [sz Charlie Conway with permission September 22, 2023 [sZ Michael Pipkin Charlie Conway Attorney for CZOT/MGS LLC and Hartford Fire Insurance Company AGREED MOTION FOR CONTINUANCE PAGE 2 CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the above and foregoing document has been forwarded to all counsel of record on the 23rd day of September 2022, in accordance with Rule 21a of the Texas Rules of Civil Procedure. VIA E-FILE Charlie Conway WT SKIP LEAKE, PC. 350 Westpark Way, Ste. 205 Euless, Texas 76040 [Si Michael T. Pipkz'n Michael T. Pipkin AGREED MOTION FOR CONTINUANCE PAGE 3 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. Mario Young on behalf of Michael Pipkin Bar No. 24122988 myoung@tfandw.com Envelope ID: 68545510 Status as of 9/23/2022 2:13 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Todd R.Nectoux tnectoux@tfandw.com 9/23/2022 9:07:03 AM SENT W T Skip Leake skip@leakelaw.com 9/23/2022 9:07:03 AM SENT Jonathan C.Conway cconway@leakelaw.com 9/23/2022 9:07:03 AM SENT 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. Mario Young on behalf of Michael Pipkin Bar No. 24122988 myoung@tfandw.com Envelope ID: 68545510 Status as of 9/23/2022 2:13 PM CST Associated Case Party: HARTFORD FIRE INSURANCE COMPANY Name BarNumber Email TimestampSubmitted Status Maribel Luzunaris Maribel.Luzunaris@thehartford.com 9/23/2022 9:07:03 AM SENT