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.
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FILED
6/25/2021 2:11 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Treva Parker-Ayodele DEPUTY
CAUSE NO. DC-20-10819
REMVER, LLC § IN THE DISTRICT COURT
§
Plaintzffi §
§
v. § 0F DALLAS COUNTY, TEXAS
§
AMSOIL INC, BRIAN BROOKS, AND §
PATRICK COWAN §
§ 298TH JUDICIAL DISTRICT COURT
Defendants. §
UNOPPOSED MOTION TO LIFT STAY
On April 21, 2021, Plaintiffs Counsel, Thompson & Knight LLP, moved to withdraw fiom
representing Plaintiff in this case and moved for a stay of all deadlines for thirty days. Plaintiff has
since obtained the undersigned counsel to represent its interests in this matter.
As Plaintiff has retained new counsel, Plaintiff moves to lift the stay. Defendants are
unopposed to the requested relief. Plaintiff respectfully requests that the Court GRANT this
motion to lift the stay so that the parties may resume the prosecution and defense of their respective
claims.
By: /s/ GeoffJ. Henley
Geoff J. Henley
HENLEY & HENLEY, P.C.
Texas SBN: 00798253
2520 Fairmount, Suite 200
Dallas, Texas 75201
P (214) 821-0222
F (214) 821-0124
ghenlev@henlevlawpc.com
UNOPPOSED MOTION TO LIFT STAY Page 1
Jonathan D. Groves
Attorney Pro Hac Vice
GROVES LAW FIRM, LLC
Colorado SBN: 24087637
85 S. Union Blvd, No. 523
Lakewood, Colorado 80228
Tel: (817)-683-7634
ionathangroveséflgroveslawfirm.com
ATTORNEYS FOR PLAINTIFF
REMVER, LLC
CERTIFICATE OF SERVICE
I hereby certify that on June 25, 2021, a true and correct copy of the foregoing motion has
been served on all counsel appearing in this matter.
/s/ GeoffJ. Henlev
Geoff J. Henley
CERTIFICATE 0F CONFERENCE
I, Geoff Henley, hereby certify to the Court that I have conferred with Mr. Alan Anderson,
counsel for Defendants, in an effort to resolve the issues contained in this motion without the
necessity of court intervention, and opposing counsel has indicated that he does not oppose this
motion.
Certified to the Day of June 25, 2021 by:
/s/ GeoffJ. Henley
Geoff J. Henley
UNOPPOSED MOTION TO LIFT 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.
Rossina Ortega on behalf of Geoff Henley
Bar No. 00798253
rortega@henleylawpc.com
Envelope ID: 54795391
Status as of 6/29/2021 11:07 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
charlene hanson chanson@henleylawpc.com 6/25/2021 2:1 1 :42 PM SENT
Justin Cohen 24078356 Justin.Cohen@tklaw.com 6/25/2021 2:11:42 PM SENT
Jonathan Groves 24087637 jonathan.groves@groveslawfirm.com 6/25/2021 2:11:42 PM SENT
Dina McKenney dina.mckenney@tklaw.com 6/25/2021 2:11:42 PM SENT
Reagan Florence rflorence@anderson-lawfirm.com 6/25/2021 2:11:42 PM SENT
Geoffrey NCourtney GNCourtney@GNCourtney.com 6/25/2021 2:11:42 PM SENT
Allan K.DuBois akd@akduboislaw.com 6/25/2021 2:11:42 PM SENT
David Fennell david.fennell@tklaw.com 6/25/2021 2:11:42 PM SENT
Alan M.Anderson aanderson@anderson-lawfirm.com 6/25/2021 2:11:42 PM SENT
Stacy Gunder stacy.gunder@tklaw.com 6/25/2021 2:11:42 PM SENT
Associated Case Party: REMVER, LLC
Name BarNumber Email TimestampSubmitted Status
Geoff Henley ghenley@henleylawpc.com 6/25/2021 2:11:42 PM SENT
Document Filed Date
June 25, 2021
Case Filing Date
August 07, 2020
Category
CNTR CNSMR COM DEBT
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FILED 6/25/2021 2:11 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Treva Parker-Ayodele DEPUTY CAUSE NO. DC-20-10819 REMVER, LLC § IN THE DISTRICT COURT § Plaintzffi § § v. § 0F DALLAS COUNTY, TEXAS § AMSOIL INC, BRIAN BROOKS, AND § PATRICK COWAN § § 298TH JUDICIAL DISTRICT COURT Defendants. § UNOPPOSED MOTION TO LIFT STAY On April 21, 2021, Plaintiffs Counsel, Thompson & Knight LLP, moved to withdraw fiom representing Plaintiff in this case and moved for a stay of all deadlines for thirty days. Plaintiff has since obtained the undersigned counsel to represent its interests in this matter. As Plaintiff has retained new counsel, Plaintiff moves to lift the stay. Defendants are unopposed to the requested relief. Plaintiff respectfully requests that the Court GRANT this motion to lift the stay so that the parties may resume the prosecution and defense of their respective claims. By: /s/ GeoffJ. Henley Geoff J. Henley HENLEY & HENLEY, P.C. Texas SBN: 00798253 2520 Fairmount, Suite 200 Dallas, Texas 75201 P (214) 821-0222 F (214) 821-0124 ghenlev@henlevlawpc.com UNOPPOSED MOTION TO LIFT STAY Page 1 Jonathan D. Groves Attorney Pro Hac Vice GROVES LAW FIRM, LLC Colorado SBN: 24087637 85 S. Union Blvd, No. 523 Lakewood, Colorado 80228 Tel: (817)-683-7634 ionathangroveséflgroveslawfirm.com ATTORNEYS FOR PLAINTIFF REMVER, LLC CERTIFICATE OF SERVICE I hereby certify that on June 25, 2021, a true and correct copy of the foregoing motion has been served on all counsel appearing in this matter. /s/ GeoffJ. Henlev Geoff J. Henley CERTIFICATE 0F CONFERENCE I, Geoff Henley, hereby certify to the Court that I have conferred with Mr. Alan Anderson, counsel for Defendants, in an effort to resolve the issues contained in this motion without the necessity of court intervention, and opposing counsel has indicated that he does not oppose this motion. Certified to the Day of June 25, 2021 by: /s/ GeoffJ. Henley Geoff J. Henley UNOPPOSED MOTION TO LIFT 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. Rossina Ortega on behalf of Geoff Henley Bar No. 00798253 rortega@henleylawpc.com Envelope ID: 54795391 Status as of 6/29/2021 11:07 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status charlene hanson chanson@henleylawpc.com 6/25/2021 2:1 1 :42 PM SENT Justin Cohen 24078356 Justin.Cohen@tklaw.com 6/25/2021 2:11:42 PM SENT Jonathan Groves 24087637 jonathan.groves@groveslawfirm.com 6/25/2021 2:11:42 PM SENT Dina McKenney dina.mckenney@tklaw.com 6/25/2021 2:11:42 PM SENT Reagan Florence rflorence@anderson-lawfirm.com 6/25/2021 2:11:42 PM SENT Geoffrey NCourtney GNCourtney@GNCourtney.com 6/25/2021 2:11:42 PM SENT Allan K.DuBois akd@akduboislaw.com 6/25/2021 2:11:42 PM SENT David Fennell david.fennell@tklaw.com 6/25/2021 2:11:42 PM SENT Alan M.Anderson aanderson@anderson-lawfirm.com 6/25/2021 2:11:42 PM SENT Stacy Gunder stacy.gunder@tklaw.com 6/25/2021 2:11:42 PM SENT Associated Case Party: REMVER, LLC Name BarNumber Email TimestampSubmitted Status Geoff Henley ghenley@henleylawpc.com 6/25/2021 2:11:42 PM SENT