On February 16, 2021 a
Motion-Secondary
was filed
involving a dispute between
La Energia Nortena, Llc,
Novoa, Humberto,
Zamarripa, Adrian,
and
Cuevas, Moises,
for OTHER (CIVIL)
in the District Court of Dallas County.
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CAUSE NO. DC-22-03103
LA ENERGIA NORTENA, LLC, § IN THE DISTRICT COURT
ADRIAN ZAMARRIPA, and §
HUMBERTO NOVOA §
§
VS. § 192“ JUDICIAL DISTRICT
§
MOISES CUEVAS, JR. § DALLAS COUNTY, TEXAS
ORDER
PLAINTIFFS’ MOTION TO CORRECT
THE COURT’S AUGUST 18, 2022 ORDER ON
DEFENDANT’S MOTION TO STAY
The Court having considered Plaintiffs’ Motion to Correct the Court’s August 18, 2022
Order on Defendant’s Motion to Stay, and Defendant’s response in opposition, the Court DENIES
Plaintiffs’ said motion.
The Court further finds that Plaintiffs and Plaintiffs’ counsel knowingly made
misrepresentations of fact in support of their Motion to Correct the Court’s August 18, 2022 Order
on Defendant’s Motion to Stay for the improper purpose of wasting this Court’s time, harassing
Defendant Cuevas, and needlessly increasing the cost of litigation in Violation of Tex. R. CiV. P.
13 and Tex. Civ. Prac. & Rem. Code § 10.001.
Accordingly, pursuant to Tex. Civ. Prac. & Rem. Code §10.002, this Court orders that once
the proceedings in the above action are resumed and the present stay of all proceeding is lifted in
the above state action in accordance with the Court’s August 18, 2022 Order on Defendant’s
Motion to Stay, the clerk is instructed to set a special hearing for Plaintiffs and Plaintiff‘s counsel
to show cause why Plaintiff‘s and Plaintiffs’ counsel conduct does not Violate Tex. R. Civ. P. 13
and Tex. Civ. Prac. & Rem. Code § 10.001 in filing and presenting their Motion to Correct.
Signed on , 2022.
JUDGE PRESIDING
Respectfully Submitted for Entry by:
DAVID CHASE LAN CARTE
Texas Bar No. 24082464
chase@1ancartelaw.com
LanCarte Law, PLLC
2817 West End Ave., Suite 126-276
Nashville, Tennessee 37203
Tel: 214-935-2430
Fax: 214-934-2450
ls/ Marcus C. Marsden, Jr.
MARCUS C. MARSDEN, JR.
State Bar No. 13014200
marcus@colanerifirm.com
THE COLANERI FIRM, P.C.
524 E. Lamar BlVd., Suite 280
Arlington, Texas 76011
Tel: 817-640-1588
Fax: 817-640-1680
ATTORNEYS FOR DEFENDANT
CERTIFICATE OF SERVICE
I do hereby certify that I have forwarded a true and correct copy of the above and foregoing
pleading in this cause to all counsel of record for the represented parties as listed below on this
September l4, 2022.
David N. CalVillo
TX State Bar No. 03673000
1200 Smith Street, Suite 1400
Houston, TX 77002
david.ca1villo@chamberlainlaw.com
Angel V. Mata
TX State Bar No. 24063 940
512 S. Fitzhugh Avenue
Dallas, TX 75223
attorney@angelmatalaw.com
Ola»
David Chase LanCarte
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.
David LanCarte
Bar No. 24082464
chase@lancartelaw.com
Envelope ID: 68262601
Status as of 9/14/2022 4:17 PM CST
Associated Case Party: MOISES CUEVAS
Name BarNumber Email TimestampSubmitted Status
David LanCarte 24082464 chase@lancartelaw.com 9/14/2022 3:58:02 PM 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.
David LanCarte
Bar No. 24082464
chase@lancartelaw.com
Envelope ID: 68262601
Status as of 9/14/2022 4:17 PM CST
Associated Case Party: HUMBERTO NOVOA
Name BarNumber Email TimestampSubmitted Status
Debbie Kennedy debbie.kennedy@chamberlainlaw.com 9/14/2022 3:58:02 PM SENT
David N.Calvillo david.ca|villo@chamberlainlaw.com 9/14/2022 3:58:02 PM SENT
Judy Rochna judy.rochna@chamberlainlaw.com 9/14/2022 3:58:02 PM SENT
Lauren Herrera lauren.herrera@chamberlainlaw.com 9/14/2022 3:58:02 PM SENT
Armando Huereca armando.huereca@chamberlainlaw.com 9/14/2022 3:58:02 PM SENT
Angel V.Mata attorney@angelmatalaw.com 9/14/2022 3:58:02 PM 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.
David LanCarte
Bar No. 24082464
chase@lancartelaw.com
Envelope ID: 68262601
Status as of 9/14/2022 4:17 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Marcus C. Marsden 13014200 marcus@colanerifirm.com 9/14/2022 3:58:02 PM SENT
Estefany Martinez martinez@angelmatalaw.com 9/14/2022 3:58:02 PM SENT
Document Filed Date
September 14, 2022
Case Filing Date
February 16, 2021
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CAUSE NO. DC-22-03103 LA ENERGIA NORTENA, LLC, § IN THE DISTRICT COURT ADRIAN ZAMARRIPA, and § HUMBERTO NOVOA § § VS. § 192“ JUDICIAL DISTRICT § MOISES CUEVAS, JR. § DALLAS COUNTY, TEXAS ORDER PLAINTIFFS’ MOTION TO CORRECT THE COURT’S AUGUST 18, 2022 ORDER ON DEFENDANT’S MOTION TO STAY The Court having considered Plaintiffs’ Motion to Correct the Court’s August 18, 2022 Order on Defendant’s Motion to Stay, and Defendant’s response in opposition, the Court DENIES Plaintiffs’ said motion. The Court further finds that Plaintiffs and Plaintiffs’ counsel knowingly made misrepresentations of fact in support of their Motion to Correct the Court’s August 18, 2022 Order on Defendant’s Motion to Stay for the improper purpose of wasting this Court’s time, harassing Defendant Cuevas, and needlessly increasing the cost of litigation in Violation of Tex. R. CiV. P. 13 and Tex. Civ. Prac. & Rem. Code § 10.001. Accordingly, pursuant to Tex. Civ. Prac. & Rem. Code §10.002, this Court orders that once the proceedings in the above action are resumed and the present stay of all proceeding is lifted in the above state action in accordance with the Court’s August 18, 2022 Order on Defendant’s Motion to Stay, the clerk is instructed to set a special hearing for Plaintiffs and Plaintiff‘s counsel to show cause why Plaintiff‘s and Plaintiffs’ counsel conduct does not Violate Tex. R. Civ. P. 13 and Tex. Civ. Prac. & Rem. Code § 10.001 in filing and presenting their Motion to Correct. Signed on , 2022. JUDGE PRESIDING Respectfully Submitted for Entry by: DAVID CHASE LAN CARTE Texas Bar No. 24082464 chase@1ancartelaw.com LanCarte Law, PLLC 2817 West End Ave., Suite 126-276 Nashville, Tennessee 37203 Tel: 214-935-2430 Fax: 214-934-2450 ls/ Marcus C. Marsden, Jr. MARCUS C. MARSDEN, JR. State Bar No. 13014200 marcus@colanerifirm.com THE COLANERI FIRM, P.C. 524 E. Lamar BlVd., Suite 280 Arlington, Texas 76011 Tel: 817-640-1588 Fax: 817-640-1680 ATTORNEYS FOR DEFENDANT CERTIFICATE OF SERVICE I do hereby certify that I have forwarded a true and correct copy of the above and foregoing pleading in this cause to all counsel of record for the represented parties as listed below on this September l4, 2022. David N. CalVillo TX State Bar No. 03673000 1200 Smith Street, Suite 1400 Houston, TX 77002 david.ca1villo@chamberlainlaw.com Angel V. Mata TX State Bar No. 24063 940 512 S. Fitzhugh Avenue Dallas, TX 75223 attorney@angelmatalaw.com Ola» David Chase LanCarte 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. David LanCarte Bar No. 24082464 chase@lancartelaw.com Envelope ID: 68262601 Status as of 9/14/2022 4:17 PM CST Associated Case Party: MOISES CUEVAS Name BarNumber Email TimestampSubmitted Status David LanCarte 24082464 chase@lancartelaw.com 9/14/2022 3:58:02 PM 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. David LanCarte Bar No. 24082464 chase@lancartelaw.com Envelope ID: 68262601 Status as of 9/14/2022 4:17 PM CST Associated Case Party: HUMBERTO NOVOA Name BarNumber Email TimestampSubmitted Status Debbie Kennedy debbie.kennedy@chamberlainlaw.com 9/14/2022 3:58:02 PM SENT David N.Calvillo david.ca|villo@chamberlainlaw.com 9/14/2022 3:58:02 PM SENT Judy Rochna judy.rochna@chamberlainlaw.com 9/14/2022 3:58:02 PM SENT Lauren Herrera lauren.herrera@chamberlainlaw.com 9/14/2022 3:58:02 PM SENT Armando Huereca armando.huereca@chamberlainlaw.com 9/14/2022 3:58:02 PM SENT Angel V.Mata attorney@angelmatalaw.com 9/14/2022 3:58:02 PM 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. David LanCarte Bar No. 24082464 chase@lancartelaw.com Envelope ID: 68262601 Status as of 9/14/2022 4:17 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Marcus C. Marsden 13014200 marcus@colanerifirm.com 9/14/2022 3:58:02 PM SENT Estefany Martinez martinez@angelmatalaw.com 9/14/2022 3:58:02 PM SENT