On October 25, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Burch, Michael P.,
and
Alcantar, Elvira Zubiri,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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FILED
DALLAS COUNTY
12/18/2019 10:29 AM
FELICIA PITRE
DISTRICT CLERK
Dorothy Strogen
N0. DC—18-16118
MICHAEL P. BURCH IN THE DISTRICT COURT
PLAINTIFF,
VS. WWWWWWW
DALLAS COUNTY, TEXAS
ELVIRA ZUBIRI ALCANTAR
DEFENDANT. 134m JUDICIAL DISTRICT
AGREED MOTION FOR CONTINUANCE
To THE HONORABLE JUDGE 0F SAID COURT:
COME NOW Plaintiff Michael P. Burch and Defendant Elvira Zubiri Alcantar by and
through their respective attorneys of record, and file this their Agreed Motion for Continuance,
and in support thereof would respectfully show the Court the following:
This case is currently set for trial the week 0f January 6, 2020. This is the first trial setting
for this case and n0 previous motions for continuance have been filed. The parties agree that
additional discovery is necessary, including party depositions, t0 evaluate the claims for mediation
purposes and, if necessary, to prepare this case for trial and have agreed to seek a continuance of
the current trial setting for a period of not less than ninety days. This Motion for Continuance is
not filed for delay only but so that justice may be done. For the reasons stated above, the Court
should remove this case for the docket for the week of January 6, 2020, and reset this matter for
trial not less than 120 days from January 6, 2020.
WHEREFORE, PREMISES CONSIDERED, Plaintiff and Defendant pray that their Agreed
Motion for Continuance be granted and that this case be removed from its current trial setting and
be reset for trial at a later date.
AGREED MOTION FOR CONTINUANCE PAGE 1
Respectfully submitted,
/s/ William A. Forteith
William A. Forteith, State Bar 7267500
BAILEY & GALYEN
4131 N. Central Exp 860
Dallas, Texas 75204
214-252-9099
214-520-9941 — fax
bforteith a1 en.com
ATTORNEY FOR PLAINTIFF
CQW
Chad Kimble, State Bar 24007483
Kyle L. Smith, State Bar 241025 12
D. Brent Beasley, State Bar 24082669
LAW OFFICE 0F CHAD KIMBLE, P.C.
1204 S. White Chapel Blvd.
Southlake, Texas 76092
eservice@chadkimblelaw.com
817.766.7488
817.423.7492 fax
ATTORNEYS FOR DEFENDANT
AGREED MOTION FOR CONTINUANCE PAGE 2
Document Filed Date
December 18, 2019
Case Filing Date
October 25, 2018
Category
MOTOR VEHICLE ACCIDENT
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FILED DALLAS COUNTY 12/18/2019 10:29 AM FELICIA PITRE DISTRICT CLERK Dorothy Strogen N0. DC—18-16118 MICHAEL P. BURCH IN THE DISTRICT COURT PLAINTIFF, VS. WWWWWWW DALLAS COUNTY, TEXAS ELVIRA ZUBIRI ALCANTAR DEFENDANT. 134m JUDICIAL DISTRICT AGREED MOTION FOR CONTINUANCE To THE HONORABLE JUDGE 0F SAID COURT: COME NOW Plaintiff Michael P. Burch and Defendant Elvira Zubiri Alcantar by and through their respective attorneys of record, and file this their Agreed Motion for Continuance, and in support thereof would respectfully show the Court the following: This case is currently set for trial the week 0f January 6, 2020. This is the first trial setting for this case and n0 previous motions for continuance have been filed. The parties agree that additional discovery is necessary, including party depositions, t0 evaluate the claims for mediation purposes and, if necessary, to prepare this case for trial and have agreed to seek a continuance of the current trial setting for a period of not less than ninety days. This Motion for Continuance is not filed for delay only but so that justice may be done. For the reasons stated above, the Court should remove this case for the docket for the week of January 6, 2020, and reset this matter for trial not less than 120 days from January 6, 2020. WHEREFORE, PREMISES CONSIDERED, Plaintiff and Defendant pray that their Agreed Motion for Continuance be granted and that this case be removed from its current trial setting and be reset for trial at a later date. AGREED MOTION FOR CONTINUANCE PAGE 1 Respectfully submitted, /s/ William A. Forteith William A. Forteith, State Bar 7267500 BAILEY & GALYEN 4131 N. Central Exp 860 Dallas, Texas 75204 214-252-9099 214-520-9941 — fax bforteith a1 en.com ATTORNEY FOR PLAINTIFF CQW Chad Kimble, State Bar 24007483 Kyle L. Smith, State Bar 241025 12 D. Brent Beasley, State Bar 24082669 LAW OFFICE 0F CHAD KIMBLE, P.C. 1204 S. White Chapel Blvd. Southlake, Texas 76092 eservice@chadkimblelaw.com 817.766.7488 817.423.7492 fax ATTORNEYS FOR DEFENDANT AGREED MOTION FOR CONTINUANCE PAGE 2