On September 28, 2022 a
Stipulation,Agreement
was filed
involving a dispute between
Norris, Stormie,
Rodriguez, Osvaldo,
and
Phan, Amy Michelle,
Rodriguez, Osvaldo,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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FILED
5/23/2023 4:43 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Dorothy Strogen DEPUTY
CAUSE NO. DC-22-13615
STORMIE NORRIS AND § IN THE DISTRICT COURT
OSVALDO RODRIGUEZ §
Plaintiffs, §
§
§
v § DALLAS COUNTY, TEXAS
§
§
AMY MICHELLE PHAN AND §
OSVALDO RODRIGUEZ, §
Defendants. § 44TH JUDICIAL DISTRICT
AGREED MOTION FOR CONTINUANCE AND AGREED MOTION
TO MODIFY DISCOVERY LEVEL
COME NOW Stormie Norris and Osvaldo Rodriguez (“Plaintiffs”) and Amy Michelle
Phan and Osvaldo Rodriguez ("Defendants") file this Agreed Motion for Continuance and would
show the Court as follows:
1. Trial in this case is currently set for trial on August 21, 2023 (“Current Trial
Setting”).
2. Plaintiffs and Defendants (the “Parties”) are in agreement that the above-entitled
and numbered cause (the “Trial”) should be continued and reset for the week of March 5, 2024.
3. On or about March 27, 2023, the parties filed the Agreed Motion to Consolidate
and Motion to Conform Style of Case. The two cases were consolidated on April 6, 2023, as per
this Honorable Court's ruling.
4. Discovery is ongoing in this matter and the Parties are in the process of
scheduling depositions.
AGREED MOTION FOR CONTINUAN CE AND AGREED MOTION TO MODIFY DISCOVERY LEVEL
Page 1 of 4
5. Additionally, the Parties agree that more time is necessary for discovery and to
attend mediation and the Parties respectfully request the Court to continue the above-entitled and
numbered cause for the same.
6. The Parties would state that this Agreed Motion for Continuance is not sought for
delay, but so that justice may be achieved.
7. Additionally, the Parties are in agreement that the discovery level should be
modified to Level 2. Plaintiff Stormie Norris initially filed the case under Discovery Level 2.
Said case was consolidated to the current case number. Prior to consolidation, all parties agreed
to modify the discovery level to Level 2 as per the Rule 190.3.
WPEREFORE, PREMISES CONSIDERED, Plaintiffs and Defendants respectfully
request that this Agreed Motion for Continuance be in all things granted, new scheduling order
be entered extending all deadlines, discovery level be modified to Level 2, and for such further
relief that Parties may be entitled.
Respectfully submitted
CHALAKI LAW, P.C.
By: /s/ Shawn Hashemi
E-service: efile@chalakilaw.com
Shawn Hashemi
Texas Bar No. 24090151
Yasamin Moussavi
Texas Bar N0. 24128646
Amber Chambers
Texas Bar No. 24100300
Sean Chalaki
Texas Bar No. 24072032
North Dallas Law Center
3234 Commander Drive, Suite 100
Carrollton, Texas 75006
Tel. 972-793-8500
AGREED MOTION FOR CONTINUAN CE AND AGREED MOTION TO MODIFY DISCOVERY LEVEL
Page 2 of 4
Fax: 800-991—6288
ATTORNEYS FOR PLAINTIFF
STORMIE NORRIS
AND
By: /s/Koryfl1ge_ry_§igned with permission)_
Kory Kingery
SBN. 2094778
RE. Lopez & Associates, P.C.
550 E. 15th Street, Suite 200
Plano, Texas 75074
service@northtxlaw.com
Tel. 469-209-7727
ATTORNEY FOR PLAINTIFF
OSVALDO RODRIGUEZ
By: /s/ John W. Breeze (Signed with permission)_
John W. Breeze
SBN. 00796248
The LeCrone Law Firm, RC.
123 North Crockett Street, Suite 200
Sherman, Texas 75090
Tel. 903-813—1900
ATTORNEY FOR DEFENDANT
AMY MICHELLE PHAN
AND
By: /s/John Couch (Sianed with permission)
John Couch
SBN. 24048407
Law Offices of Tammi J. Enochs
450 Century Parkway, Suite 250
Allen, Texas 75013
john.couch@usaa.com
Tel. 210-829—5566
ATTORNEY FOR DEFENDANT
OSVALDO RODRIGUEZ
AGREED MOTION FOR CONTINUAN CE AND AGREED MOTION TO MODIFY DISCOVERY LEVEL
Page 3 of 4
CERTIFICATE OF SERVICE
I hereby certify that a true a correct copy 0f the foregoing Agreed Motion for
Continuance was forwarded, Via E-Service, to all counsels of record on this 23rd day of May
2023, as indicated below:
Kory Kingery
R.E. Lopez & Associates, P.C.
550 E. 15th Street, Suite 200
Plano, Texas 75074
service(a)northtxlaw.com
Tel. 469-209—7727
Attorney for Plaintiff Osvaldo Rodriguez
John W. Breeze
The LeCrone Law Firm, P.C.
123 North Crockett Street, Suite 200
Sherman, Texas 75090
eservice@lecronelaw.com
Tel. 903-813-1900
Attorney for Defendant Amy Phan
John Couch
Law Offices of Tammi J. Enochs
450 Century Parkway, Suite 250
Allen, Texas 75013
john.couch@usaa.com
Tel. 210-829—5566
Attorney for Defendant Osvaldo Rodriguez
/s/ Shawn Hashemi
Shawn Hashemi
AGREED MOTION FOR CONTINUAN CE AND AGREED MOTION TO MODIFY DISCOVERY LEVEL
Page 4 of 4
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.
Chalaki Law E-Service on behalf of Shawn Hashemi
Bar No. 24090151
efile@chalakilaw.com
Envelope ID: 75932927
Filing Code Description: Motion - Continuance
Filing Description: - AGREED / & AGREED MOTION TO MODIFY
DISCOVERY LEVEL
Status as of 5/24/2023 10:19 AM CST
Associated Case Party: OSVALDO RODRIGUEZ
Name BarNumber Email TimestampSubmitted Status
KORY KINGERY SERVICE@NORTHTXLAW.COM 5/23/2023 4:43:22 PM SENT
Associated Case Party: AMYMichellePHAN
Name BarNumber Email TimestampSubmitted Status
John W.Breeze eservice@lecronelaw.com 5/23/2023 4:43:22 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Shawn Hashemi efile@chalakilaw.com 5/23/2023 4:43:22 PM SENT
John Couch john.couch@usaa.com 5/23/2023 4:43:22 PM SENT
Document Filed Date
May 23, 2023
Case Filing Date
September 28, 2022
Category
MOTOR VEHICLE ACCIDENT
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FILED 5/23/2023 4:43 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Dorothy Strogen DEPUTY CAUSE NO. DC-22-13615 STORMIE NORRIS AND § IN THE DISTRICT COURT OSVALDO RODRIGUEZ § Plaintiffs, § § § v § DALLAS COUNTY, TEXAS § § AMY MICHELLE PHAN AND § OSVALDO RODRIGUEZ, § Defendants. § 44TH JUDICIAL DISTRICT AGREED MOTION FOR CONTINUANCE AND AGREED MOTION TO MODIFY DISCOVERY LEVEL COME NOW Stormie Norris and Osvaldo Rodriguez (“Plaintiffs”) and Amy Michelle Phan and Osvaldo Rodriguez ("Defendants") file this Agreed Motion for Continuance and would show the Court as follows: 1. Trial in this case is currently set for trial on August 21, 2023 (“Current Trial Setting”). 2. Plaintiffs and Defendants (the “Parties”) are in agreement that the above-entitled and numbered cause (the “Trial”) should be continued and reset for the week of March 5, 2024. 3. On or about March 27, 2023, the parties filed the Agreed Motion to Consolidate and Motion to Conform Style of Case. The two cases were consolidated on April 6, 2023, as per this Honorable Court's ruling. 4. Discovery is ongoing in this matter and the Parties are in the process of scheduling depositions. AGREED MOTION FOR CONTINUAN CE AND AGREED MOTION TO MODIFY DISCOVERY LEVEL Page 1 of 4 5. Additionally, the Parties agree that more time is necessary for discovery and to attend mediation and the Parties respectfully request the Court to continue the above-entitled and numbered cause for the same. 6. The Parties would state that this Agreed Motion for Continuance is not sought for delay, but so that justice may be achieved. 7. Additionally, the Parties are in agreement that the discovery level should be modified to Level 2. Plaintiff Stormie Norris initially filed the case under Discovery Level 2. Said case was consolidated to the current case number. Prior to consolidation, all parties agreed to modify the discovery level to Level 2 as per the Rule 190.3. WPEREFORE, PREMISES CONSIDERED, Plaintiffs and Defendants respectfully request that this Agreed Motion for Continuance be in all things granted, new scheduling order be entered extending all deadlines, discovery level be modified to Level 2, and for such further relief that Parties may be entitled. Respectfully submitted CHALAKI LAW, P.C. By: /s/ Shawn Hashemi E-service: efile@chalakilaw.com Shawn Hashemi Texas Bar No. 24090151 Yasamin Moussavi Texas Bar N0. 24128646 Amber Chambers Texas Bar No. 24100300 Sean Chalaki Texas Bar No. 24072032 North Dallas Law Center 3234 Commander Drive, Suite 100 Carrollton, Texas 75006 Tel. 972-793-8500 AGREED MOTION FOR CONTINUAN CE AND AGREED MOTION TO MODIFY DISCOVERY LEVEL Page 2 of 4 Fax: 800-991—6288 ATTORNEYS FOR PLAINTIFF STORMIE NORRIS AND By: /s/Koryfl1ge_ry_§igned with permission)_ Kory Kingery SBN. 2094778 RE. Lopez & Associates, P.C. 550 E. 15th Street, Suite 200 Plano, Texas 75074 service@northtxlaw.com Tel. 469-209-7727 ATTORNEY FOR PLAINTIFF OSVALDO RODRIGUEZ By: /s/ John W. Breeze (Signed with permission)_ John W. Breeze SBN. 00796248 The LeCrone Law Firm, RC. 123 North Crockett Street, Suite 200 Sherman, Texas 75090 Tel. 903-813—1900 ATTORNEY FOR DEFENDANT AMY MICHELLE PHAN AND By: /s/John Couch (Sianed with permission) John Couch SBN. 24048407 Law Offices of Tammi J. Enochs 450 Century Parkway, Suite 250 Allen, Texas 75013 john.couch@usaa.com Tel. 210-829—5566 ATTORNEY FOR DEFENDANT OSVALDO RODRIGUEZ AGREED MOTION FOR CONTINUAN CE AND AGREED MOTION TO MODIFY DISCOVERY LEVEL Page 3 of 4 CERTIFICATE OF SERVICE I hereby certify that a true a correct copy 0f the foregoing Agreed Motion for Continuance was forwarded, Via E-Service, to all counsels of record on this 23rd day of May 2023, as indicated below: Kory Kingery R.E. Lopez & Associates, P.C. 550 E. 15th Street, Suite 200 Plano, Texas 75074 service(a)northtxlaw.com Tel. 469-209—7727 Attorney for Plaintiff Osvaldo Rodriguez John W. Breeze The LeCrone Law Firm, P.C. 123 North Crockett Street, Suite 200 Sherman, Texas 75090 eservice@lecronelaw.com Tel. 903-813-1900 Attorney for Defendant Amy Phan John Couch Law Offices of Tammi J. Enochs 450 Century Parkway, Suite 250 Allen, Texas 75013 john.couch@usaa.com Tel. 210-829—5566 Attorney for Defendant Osvaldo Rodriguez /s/ Shawn Hashemi Shawn Hashemi AGREED MOTION FOR CONTINUAN CE AND AGREED MOTION TO MODIFY DISCOVERY LEVEL Page 4 of 4 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. Chalaki Law E-Service on behalf of Shawn Hashemi Bar No. 24090151 efile@chalakilaw.com Envelope ID: 75932927 Filing Code Description: Motion - Continuance Filing Description: - AGREED / & AGREED MOTION TO MODIFY DISCOVERY LEVEL Status as of 5/24/2023 10:19 AM CST Associated Case Party: OSVALDO RODRIGUEZ Name BarNumber Email TimestampSubmitted Status KORY KINGERY SERVICE@NORTHTXLAW.COM 5/23/2023 4:43:22 PM SENT Associated Case Party: AMYMichellePHAN Name BarNumber Email TimestampSubmitted Status John W.Breeze eservice@lecronelaw.com 5/23/2023 4:43:22 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Shawn Hashemi efile@chalakilaw.com 5/23/2023 4:43:22 PM SENT John Couch john.couch@usaa.com 5/23/2023 4:43:22 PM SENT