On August 07, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Remver, Llc,
and
Amsoil Inc.,
Brooks, Brian,
Cowan, Patrick,
Tsg Trinity Security Group Llc,
Tubaiste,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
Preview
FILED
4/21/2021 10:03 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Jeremy Jones DEPUTY
CAUSE NO. DC—20—10819
REM VER, LLC § IN THE DISTRICT COURT
§
Plain tiff, §
§
v. § 0F DALLAS COUNTY, TEXAS
§
AMSOIL INC, BRIAN BROOKS, AND §
PATRICK COWAN §
§ 298TH JUDICIAL DISTRICT COURT
Defendants. §
UNOPPOSED MOTION TO STAY
Plaintiff’s Counsel, Thompson & Knight LLP, has recently moved to withdraw from
representing Plaintiff in this case. Plaintiff now moves for a stay of all deadlines for thirty days,
with the exception that Plaintiff has agreed to respond to outstanding discovery requests by May
14, 2021. Plaintiff seeks this stayin order to retain new counsel, who will need some time to come
up to speed on the case. This stay does not impact any of the proposed dates in the Parties’ recently
filed Joint Motion to Continue Trial Setting and Enter Agreed Amended Scheduling Order.
Defendants are unopposed to the requested stay. Plaintiff respectfully requests that the Court grant
this Motion and stay the case for thirty days.
UNOPPOSED MOTION T0 STAY — Page 1
By: THOMPSON & KNIGHT LLP
/s/ Justin S. Cohen
Justin S. Cohen
State Bar No. 24078356
E tin.cohen@tk1aw.com
Dina W. McKenney
State Bar No. 24092809
Dina.mckenney(a)tk1aw.com
1722 Routh Street, Suite 1500
Dallas, Texas 75201
Phone: (214) 969-1700
Fax: (214) 969-1751
ATTORNEYS FOR PLAINTIFF
(Motion to Withdraw Pending)
CERTIFICATE OF SERVICE
Ihereby certify that on April 21, 2021, a true and correct copy of the foregoing motion will
be served on counsel for Defendants.
/s/ Justin S. Cohen
Justin S. Cohen
CERTIFICATE OF CONFERENCE
I hereby certify that I conferred with counsel for Defendants, who indicated that
Defendants are unopposed to the relief sought.
/s/ Justin S. Cohen
Justin S. Cohen
UNOPPOSED MOTION TO STAY — Page 2
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 Fennell on behalf of Justin Cohen
Bar No. 24078356
david.fennell@tklaw.com
Envelope ID: 52668914
Status as of 4/21/2021 10:41 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Justin Cohen 24078356 Justin.Cohen@tklaw.com 4/21/2021 10:03:27 AM SENT
Dina McKenney dina.mckenney@tklaw.com 4/21/2021 10:03:27 AM SENT
Allan K.DuBois akd@akduboislaw.com 4/21/2021 10:03:27 AM SENT
David Fennell david.fennell@tklaw.com 4/21/2021 10:03:27 AM SENT
Alan M.Anderson aanderson@anderson-lawfirm.com 4/21/2021 10:03:27 AM SENT
Reagan Florence rflorence@anderson-lawfirm.com 4/21/2021 10:03:27 AM SENT
Geoffrey NCourtney GNCourtney@GNCourtney.com 4/21/2021 10:03:27 AM SENT
Stacy Gunder stacy.gunder@tklaw.com 4/21/2021 10:03:27 AM SENT
Document Filed Date
April 21, 2021
Case Filing Date
August 07, 2020
Category
CNTR CNSMR COM DEBT
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FILED 4/21/2021 10:03 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Jeremy Jones DEPUTY CAUSE NO. DC—20—10819 REM VER, LLC § IN THE DISTRICT COURT § Plain tiff, § § v. § 0F DALLAS COUNTY, TEXAS § AMSOIL INC, BRIAN BROOKS, AND § PATRICK COWAN § § 298TH JUDICIAL DISTRICT COURT Defendants. § UNOPPOSED MOTION TO STAY Plaintiff’s Counsel, Thompson & Knight LLP, has recently moved to withdraw from representing Plaintiff in this case. Plaintiff now moves for a stay of all deadlines for thirty days, with the exception that Plaintiff has agreed to respond to outstanding discovery requests by May 14, 2021. Plaintiff seeks this stayin order to retain new counsel, who will need some time to come up to speed on the case. This stay does not impact any of the proposed dates in the Parties’ recently filed Joint Motion to Continue Trial Setting and Enter Agreed Amended Scheduling Order. Defendants are unopposed to the requested stay. Plaintiff respectfully requests that the Court grant this Motion and stay the case for thirty days. UNOPPOSED MOTION T0 STAY — Page 1 By: THOMPSON & KNIGHT LLP /s/ Justin S. Cohen Justin S. Cohen State Bar No. 24078356 E tin.cohen@tk1aw.com Dina W. McKenney State Bar No. 24092809 Dina.mckenney(a)tk1aw.com 1722 Routh Street, Suite 1500 Dallas, Texas 75201 Phone: (214) 969-1700 Fax: (214) 969-1751 ATTORNEYS FOR PLAINTIFF (Motion to Withdraw Pending) CERTIFICATE OF SERVICE Ihereby certify that on April 21, 2021, a true and correct copy of the foregoing motion will be served on counsel for Defendants. /s/ Justin S. Cohen Justin S. Cohen CERTIFICATE OF CONFERENCE I hereby certify that I conferred with counsel for Defendants, who indicated that Defendants are unopposed to the relief sought. /s/ Justin S. Cohen Justin S. Cohen UNOPPOSED MOTION TO STAY — Page 2 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 Fennell on behalf of Justin Cohen Bar No. 24078356 david.fennell@tklaw.com Envelope ID: 52668914 Status as of 4/21/2021 10:41 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Justin Cohen 24078356 Justin.Cohen@tklaw.com 4/21/2021 10:03:27 AM SENT Dina McKenney dina.mckenney@tklaw.com 4/21/2021 10:03:27 AM SENT Allan K.DuBois akd@akduboislaw.com 4/21/2021 10:03:27 AM SENT David Fennell david.fennell@tklaw.com 4/21/2021 10:03:27 AM SENT Alan M.Anderson aanderson@anderson-lawfirm.com 4/21/2021 10:03:27 AM SENT Reagan Florence rflorence@anderson-lawfirm.com 4/21/2021 10:03:27 AM SENT Geoffrey NCourtney GNCourtney@GNCourtney.com 4/21/2021 10:03:27 AM SENT Stacy Gunder stacy.gunder@tklaw.com 4/21/2021 10:03:27 AM SENT