On May 15, 2019 a
Motion-Secondary
was filed
involving a dispute between
Investment Retrievers, Inc.,
and
Espinoza, Gabriela,
Espinoza Torres, Jorge L,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
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FILED
3/1 1/2020 11:09 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Nannette Bryant DEPUTY
N0. DC-19-06955
INVESTMENT RETRIEVERS *
INC. In the District Court
V.
298th Judicial District
GABRIELA ESPINOZA a/k/a
GABRIELA MARTINEZ and JORGE *********
L. ESPINOZA TORRES a/k/a JORGE
ESPINOZA TORRES a/k/a JORGE E.
TORRES a/k/a JORGE ESPINOZA
a/k/a JORGE TORRES Dallas County, Texas
DEFENDANTS’ AMENDED RESPONSE TO PLAINTIFF’S
DISINGENUOUS MOTION FOR MEDIATION REHEARING
T0 THE HONORABLE JUDGE 0F SAID COURT:
COMES NOW, Defendants Gabriela Espinoza and Jorge Espinoza and respond to the
Plaintiff’s Motion for Rehearing. Any decision to limit the Court’s business should be done by
the Supreme Court 0f Texas, 0r at the least by the Dallas County Judge. It should not be done
piecemeal. Furthermore, Plaintiff has not indicated that it has stopped its employees from
traveling outside California. There is no affidavit from its employees or management that they
have limited their business or personal travel. The attorney signator of the emergency motion has
made it clear in the past that he Will not attend any hearing 0n these motions. The emergency
motion is an effort at subterfuge and is disingenuous. If Plaintiffs motion were granted, then it
would be used t0 even allow Dallas County jurors to quit coming to court house as well. We
should only make such a change if the Dallas County administration changed the policy.
There is no alleged quarantine 0f Plaintiff” s offices or its employees; however, Plaintiff is
free t0 dismiss the case and refile When it allegedly feels safe.
Amended Response t0 Plaintiff’ s Motion for Mediation Rehearing - Page 1 0f 2
Respectfully submitted,
EDDLEMAN & CLARK
4627 North Central Expressway
Knox Central Place, Suite 2000
Dallas, Texas 75205-4022
Phone 214.528.2400
Fax 214.528.2434
RMC@R0bertMClark.net
WW. M
ROBERT M. CLARK
State Bar No. 04298200
Attorney for Defendants
Cettificate 0f Service
I copy of the above was served on counsel for Plaintiff, Carl Tucker, 2028 E.
certify that a true
Ben White TX 78741, Fax 214.594.7862, ctuckerlaw mai1.com in
B1Vd., #240-1650, Austin,
accordance With Rule 21a 0f the Texas Rules osz'vz'l Procedure on the 11th day of March, 2020.
Robert
WW. 4M
M. Clark
Amended Response to Plaintiff’s Motion for Mediation Rehearing - Page 2 0f 2
Document Filed Date
March 11, 2020
Case Filing Date
May 15, 2019
Category
CNTR CNSMR COM DEBT
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FILED 3/1 1/2020 11:09 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Nannette Bryant DEPUTY N0. DC-19-06955 INVESTMENT RETRIEVERS * INC. In the District Court V. 298th Judicial District GABRIELA ESPINOZA a/k/a GABRIELA MARTINEZ and JORGE ********* L. ESPINOZA TORRES a/k/a JORGE ESPINOZA TORRES a/k/a JORGE E. TORRES a/k/a JORGE ESPINOZA a/k/a JORGE TORRES Dallas County, Texas DEFENDANTS’ AMENDED RESPONSE TO PLAINTIFF’S DISINGENUOUS MOTION FOR MEDIATION REHEARING T0 THE HONORABLE JUDGE 0F SAID COURT: COMES NOW, Defendants Gabriela Espinoza and Jorge Espinoza and respond to the Plaintiff’s Motion for Rehearing. Any decision to limit the Court’s business should be done by the Supreme Court 0f Texas, 0r at the least by the Dallas County Judge. It should not be done piecemeal. Furthermore, Plaintiff has not indicated that it has stopped its employees from traveling outside California. There is no affidavit from its employees or management that they have limited their business or personal travel. The attorney signator of the emergency motion has made it clear in the past that he Will not attend any hearing 0n these motions. The emergency motion is an effort at subterfuge and is disingenuous. If Plaintiffs motion were granted, then it would be used t0 even allow Dallas County jurors to quit coming to court house as well. We should only make such a change if the Dallas County administration changed the policy. There is no alleged quarantine 0f Plaintiff” s offices or its employees; however, Plaintiff is free t0 dismiss the case and refile When it allegedly feels safe. Amended Response t0 Plaintiff’ s Motion for Mediation Rehearing - Page 1 0f 2 Respectfully submitted, EDDLEMAN & CLARK 4627 North Central Expressway Knox Central Place, Suite 2000 Dallas, Texas 75205-4022 Phone 214.528.2400 Fax 214.528.2434 RMC@R0bertMClark.net WW. M ROBERT M. CLARK State Bar No. 04298200 Attorney for Defendants Cettificate 0f Service I copy of the above was served on counsel for Plaintiff, Carl Tucker, 2028 E. certify that a true Ben White TX 78741, Fax 214.594.7862, ctuckerlaw mai1.com in B1Vd., #240-1650, Austin, accordance With Rule 21a 0f the Texas Rules osz'vz'l Procedure on the 11th day of March, 2020. Robert WW. 4M M. Clark Amended Response to Plaintiff’s Motion for Mediation Rehearing - Page 2 0f 2