On October 31, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Salinas, Paul Anthony,
and
Salinas, Savannah Manrique,
for Divorce - No Children (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Filed
7/31/2020 12:32 PM
Hidalgo County District Clerks
Reviewed By: Raul Hernandez
CAUSE NO. C-2 1 90-20-B
CHRISTOPHER DE LEON D/B/A IN THE DISTRICT COURT
DE LEON AIRCRAFT MAINTENANCE
PROFESSIONAL,
Plaintifif
OOOWDOODOOOWDOmOOOWDOODOOO
vs. 93rd JUDICIAL DISTRICT
CITY 0F WESLACO and WESLACO
MID VALLEY AIRPORT,
Defendants. HIDALGO COUNTY, TEXAS
PLAINTIFF’S MOTION FOR CONTINUANCE
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW Plaintiff, Christopher de Leon D/B/A De Leon Aircraft Maintenance
Professional, and files this “Plaintiff s Motion for Continuance” and would respectfully show unto
the Court as follows:
This case is currently set for trial 0n August 6, 2020. This lawsuit was filed 0n June 24,
2020. On June 24, 2020, Plaintiff filed “Plaintiff s Original Petition, Application for Temporary
Restraining Order, Temporary Injunction and Permanent Injunction.” On July 10, 2020
Defendants’ filed their Original Answer. On July 13, 2020, the Court granted Plaintiffs
Application for Temporary Injunction.
The parties need additional time to conduct discovery which has been hampered both by
the ongoing pandemic as well as the recent effects 0f Hurricane Hanna 0n South Texas. Plaintiff
intends on conducting written discovery and anticipates the need for one t0 two depositions.
Further, after adequate time t0 conduct said discovery, Plaintiff would like t0 arrange a mediation
for the parties t0 attempt t0 resolve this matter Without the need further litigation. This Motion for
Continuance is not sought for the purposes of delay but so that justice may be done.
As such, additional time is needed t0 conduct discovery, take the necessary depositions,
Electronically Filed
7/31/2020 12:32 PM
Hidalgo County District Clerks
Reviewed By: Raul Hernandez
and to mediate this case.
WHEREFORE, PREMISES CONSIDERED, and for the foregoing reasons, Plaintiffprays
this Court grant his Motion for Continuance, reset trial for February 2021, and for such other and
further relief to which he may be entitled, either at law 0r in equity.
Respectfully submitted,
DE LA GARZA LAW FIRM
By: /s/Rafael de la Garza
Rafael de 1a Garza
State Bar N0. 24076343
4919 South Jackson Rd.
Edinburg, Texas 78539
Telephone: (956) 533-1426
Fax: (956) 284-05 1 8
E-mail: rdlglaw@gmail.com
Electronically Filed
7/31/2020 12:32 PM
Hidalgo County District Clerks
Reviewed By: Raul Hernandez
CERTIFICATE OF SERVICE
I, Rafael de 1a Garza, hereby certify that on July 31, 2020, a true and correct copy 0f the
foregoing instrument was served 0n the following attorneys 0f record as follows:
VIA E-MAIL: rsandoval®r0flln.c0m
Rose Conrad-Sandoval
Roerig, Oliveira & Fisher, LLP
10225 N. 10th St.
McAllen, Texas 78504
Counselfor Defendants
VIA E-MAIL: iuanegonzalez@ieglaw.net
Juan E. Gonzalez
Law Office 0f Juan E. Gonzalez
31 10 E. Bus. Hwy. 83
Weslaco, Texas 78596
/S/Rafael de la Garza
RAFAEL DE LA GARZA
Document Filed Date
July 31, 2020
Case Filing Date
October 31, 2018
Category
Divorce - No Children (OCA)
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Electronically Filed 7/31/2020 12:32 PM Hidalgo County District Clerks Reviewed By: Raul Hernandez CAUSE NO. C-2 1 90-20-B CHRISTOPHER DE LEON D/B/A IN THE DISTRICT COURT DE LEON AIRCRAFT MAINTENANCE PROFESSIONAL, Plaintifif OOOWDOODOOOWDOmOOOWDOODOOO vs. 93rd JUDICIAL DISTRICT CITY 0F WESLACO and WESLACO MID VALLEY AIRPORT, Defendants. HIDALGO COUNTY, TEXAS PLAINTIFF’S MOTION FOR CONTINUANCE TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW Plaintiff, Christopher de Leon D/B/A De Leon Aircraft Maintenance Professional, and files this “Plaintiff s Motion for Continuance” and would respectfully show unto the Court as follows: This case is currently set for trial 0n August 6, 2020. This lawsuit was filed 0n June 24, 2020. On June 24, 2020, Plaintiff filed “Plaintiff s Original Petition, Application for Temporary Restraining Order, Temporary Injunction and Permanent Injunction.” On July 10, 2020 Defendants’ filed their Original Answer. On July 13, 2020, the Court granted Plaintiffs Application for Temporary Injunction. The parties need additional time to conduct discovery which has been hampered both by the ongoing pandemic as well as the recent effects 0f Hurricane Hanna 0n South Texas. Plaintiff intends on conducting written discovery and anticipates the need for one t0 two depositions. Further, after adequate time t0 conduct said discovery, Plaintiff would like t0 arrange a mediation for the parties t0 attempt t0 resolve this matter Without the need further litigation. This Motion for Continuance is not sought for the purposes of delay but so that justice may be done. As such, additional time is needed t0 conduct discovery, take the necessary depositions, Electronically Filed 7/31/2020 12:32 PM Hidalgo County District Clerks Reviewed By: Raul Hernandez and to mediate this case. WHEREFORE, PREMISES CONSIDERED, and for the foregoing reasons, Plaintiffprays this Court grant his Motion for Continuance, reset trial for February 2021, and for such other and further relief to which he may be entitled, either at law 0r in equity. Respectfully submitted, DE LA GARZA LAW FIRM By: /s/Rafael de la Garza Rafael de 1a Garza State Bar N0. 24076343 4919 South Jackson Rd. Edinburg, Texas 78539 Telephone: (956) 533-1426 Fax: (956) 284-05 1 8 E-mail: rdlglaw@gmail.com Electronically Filed 7/31/2020 12:32 PM Hidalgo County District Clerks Reviewed By: Raul Hernandez CERTIFICATE OF SERVICE I, Rafael de 1a Garza, hereby certify that on July 31, 2020, a true and correct copy 0f the foregoing instrument was served 0n the following attorneys 0f record as follows: VIA E-MAIL: rsandoval®r0flln.c0m Rose Conrad-Sandoval Roerig, Oliveira & Fisher, LLP 10225 N. 10th St. McAllen, Texas 78504 Counselfor Defendants VIA E-MAIL: iuanegonzalez@ieglaw.net Juan E. Gonzalez Law Office 0f Juan E. Gonzalez 31 10 E. Bus. Hwy. 83 Weslaco, Texas 78596 /S/Rafael de la Garza RAFAEL DE LA GARZA