On December 29, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Medel, Paola,
and
Holbrook, Nicholas,
for Injury/Damage - Motor Vehicle
in the District Court of Galveston County.
Preview
Filed: 1/25/2019 4:05 PM
J OHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 30691052
By: Shailja Dixit
1/25/2019 4:08 PM
CAUSE NO. 17-CV-1561
PAOLA MEDEL IN THE DISTRICT COURT OF
Plaintiff,
VS. GALVESTON COUNTY, TEXAS
NICHOLAS HOLBROOK
Defendant. § 4228” JUDICIAL DISTRICT
JOINT MOTION FOR CONTINUANCE
TO THE HONORABLE JUDGE OF SAID COURT:
COME NOW Plaintiff, Paola Medel, and Defendant, Nicholas Holbrook, and file
this Joint Motion for Continuance and as grounds therefore would show the Court as
follows:
I
This case is presently set on the court’s docket for trial on Monday, February 4,
2019. The parties need additional time to conduct discovery. Counsel respectfully request
that this case be reset on the Court’s trial docket at least 90 days out.
IL.
This continuance is not sought for delay, but so that justice may be done.
WHEREFORE, PREMISES CONSIDERED, Plaintiff and Defendant respectfully
pray that this Honorable Court grant this Motion for Continuance from the present trial
setting, and for such other and further relief to which they may show themselves justly
entitled.
Respectfully submitted,
LEWIS & WILLIAMS
‘
By:
Wade Williams
State Bar No. 21582900
1014 Hercules Avenue
Houston, Texas 77058
281.652.5509
281.652.5517/Fax
wwilliams@lewisandwilliams.com
-service@lewisandwilliams.com
Attorney for Defendant,
Nicholas Holbrook
MESTEMAKER & STRAUB
By:
Norman Straub
(
State Bar No. 00793002
3100 Timmons Lane, Suite 455
Houston, Texas 77027
713.626.8900
713.626.8910/Fax
straub@mandsattorneys.com
CERTIFICATE OF SERVICE
This pleading was served in compliance with Rules 21 and 21a of the Texas Rules of
Civil Procedure on the 25th day of January, 2019.
Wade bdibhane
Document Filed Date
January 25, 2019
Case Filing Date
December 29, 2017
Category
Injury/Damage - Motor Vehicle
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Preview
Filed: 1/25/2019 4:05 PM J OHN D. KINARD - District Clerk Galveston County, Texas Envelope No. 30691052 By: Shailja Dixit 1/25/2019 4:08 PM CAUSE NO. 17-CV-1561 PAOLA MEDEL IN THE DISTRICT COURT OF Plaintiff, VS. GALVESTON COUNTY, TEXAS NICHOLAS HOLBROOK Defendant. § 4228” JUDICIAL DISTRICT JOINT MOTION FOR CONTINUANCE TO THE HONORABLE JUDGE OF SAID COURT: COME NOW Plaintiff, Paola Medel, and Defendant, Nicholas Holbrook, and file this Joint Motion for Continuance and as grounds therefore would show the Court as follows: I This case is presently set on the court’s docket for trial on Monday, February 4, 2019. The parties need additional time to conduct discovery. Counsel respectfully request that this case be reset on the Court’s trial docket at least 90 days out. IL. This continuance is not sought for delay, but so that justice may be done. WHEREFORE, PREMISES CONSIDERED, Plaintiff and Defendant respectfully pray that this Honorable Court grant this Motion for Continuance from the present trial setting, and for such other and further relief to which they may show themselves justly entitled. Respectfully submitted, LEWIS & WILLIAMS ‘ By: Wade Williams State Bar No. 21582900 1014 Hercules Avenue Houston, Texas 77058 281.652.5509 281.652.5517/Fax wwilliams@lewisandwilliams.com -service@lewisandwilliams.com Attorney for Defendant, Nicholas Holbrook MESTEMAKER & STRAUB By: Norman Straub ( State Bar No. 00793002 3100 Timmons Lane, Suite 455 Houston, Texas 77027 713.626.8900 713.626.8910/Fax straub@mandsattorneys.com CERTIFICATE OF SERVICE This pleading was served in compliance with Rules 21 and 21a of the Texas Rules of Civil Procedure on the 25th day of January, 2019. Wade bdibhane