On June 17, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Lakeside Lutheran Church,
and
Eco Restoration & Cleaning Services,
Family Promise Of Clear Creek,
for Real Property - Other Real Property - Ownership/Title
in the District Court of Galveston County.
Preview
Filed: 1/21/2022 3:15 PM
JOHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 61044166
By: Shailja Dixit
1/21/2022 3:21 PM
NO. 21-CV-0857
LAKESIDE LUTHERAN CHURCH § IN THE DISTRICT COURT
Plaintiff, §
§
V. § 122nd JUDICIAL DISTRICT
§
ECO RESTORATION & CLEANING §
SERVICES §
Defendant. § OF GALVESTON COUNTY, TEXAS
PLAINTIFF'S MOTION FOR NON-SUIT
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES Plaintiff, Lakeside Lutheran Church, as Movant herein, and brings this
Motion for Non-Suit, and in support thereof, shows the court the following:
I.
Movant filed the above-entitled and numbered cause against Defendant Family Promise
of Clear Lake. Movant requests that the Court enter a non-suit against Family Promise of Clear
Lake, with prejudice to refile same with costs of suit taxed against Movant.
WHEREFORE, PREMISES CONSIDERED, Movant prays the Court grants
this motion and enters an Order granting the non-suit as requested herein, and for such other
and further relief that may be awarded at law or in equity.
Respectfully submitted,
By:
John H. Moon III
Texas Bar No. 24071114
Email: jmoon@moonlawfirm.com
1111 Fairmont Parkway
PASADENA, TX 77504
Tel. (713) 999-9398
Fax. (832) 383-9795
Attorney for Lakeside Lutheran Church
1|Page
CERTIFICATE OF SERVICE
I certify that on January 21, 2022 at 2:00 a true and correct copy of Plaintiff's Motion for
Non-Suit was served on Fred Shuchart electronically at Fred.Shuchart@cooperscully.com.
John H. Moon III
E-mail:jmoon@moonlawfirm.com
2|Page
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.
John Moon on behalf of John Moon
Bar No. 24071114
jmoon@moonlawfirm.com
Envelope ID: 61044166
Status as of 1/21/2022 3:21 PM CST
Associated Case Party: Lakeside Lutheran Church
Name BarNumber Email TimestampSubmitted Status
John H. Moon, III jmoon@moonlawfirm.com 1/21/2022 3:15:33 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
E. AaronCartwright Aaron@EACLawyer.com 1/21/2022 3:15:33 PM SENT
Laurel AaronCurtis laurel@eaclawyer.com 1/21/2022 3:15:33 PM SENT
Heather AaronPitcher info@eaclawyer.com 1/21/2022 3:15:33 PM SENT
Document Filed Date
January 21, 2022
Case Filing Date
June 17, 2021
Category
Real Property - Other Real Property - Ownership/Title
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Preview
Filed: 1/21/2022 3:15 PM JOHN D. KINARD - District Clerk Galveston County, Texas Envelope No. 61044166 By: Shailja Dixit 1/21/2022 3:21 PM NO. 21-CV-0857 LAKESIDE LUTHERAN CHURCH § IN THE DISTRICT COURT Plaintiff, § § V. § 122nd JUDICIAL DISTRICT § ECO RESTORATION & CLEANING § SERVICES § Defendant. § OF GALVESTON COUNTY, TEXAS PLAINTIFF'S MOTION FOR NON-SUIT TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES Plaintiff, Lakeside Lutheran Church, as Movant herein, and brings this Motion for Non-Suit, and in support thereof, shows the court the following: I. Movant filed the above-entitled and numbered cause against Defendant Family Promise of Clear Lake. Movant requests that the Court enter a non-suit against Family Promise of Clear Lake, with prejudice to refile same with costs of suit taxed against Movant. WHEREFORE, PREMISES CONSIDERED, Movant prays the Court grants this motion and enters an Order granting the non-suit as requested herein, and for such other and further relief that may be awarded at law or in equity. Respectfully submitted, By: John H. Moon III Texas Bar No. 24071114 Email: jmoon@moonlawfirm.com 1111 Fairmont Parkway PASADENA, TX 77504 Tel. (713) 999-9398 Fax. (832) 383-9795 Attorney for Lakeside Lutheran Church 1|Page CERTIFICATE OF SERVICE I certify that on January 21, 2022 at 2:00 a true and correct copy of Plaintiff's Motion for Non-Suit was served on Fred Shuchart electronically at Fred.Shuchart@cooperscully.com. John H. Moon III E-mail:jmoon@moonlawfirm.com 2|Page 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. John Moon on behalf of John Moon Bar No. 24071114 jmoon@moonlawfirm.com Envelope ID: 61044166 Status as of 1/21/2022 3:21 PM CST Associated Case Party: Lakeside Lutheran Church Name BarNumber Email TimestampSubmitted Status John H. Moon, III jmoon@moonlawfirm.com 1/21/2022 3:15:33 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status E. AaronCartwright Aaron@EACLawyer.com 1/21/2022 3:15:33 PM SENT Laurel AaronCurtis laurel@eaclawyer.com 1/21/2022 3:15:33 PM SENT Heather AaronPitcher info@eaclawyer.com 1/21/2022 3:15:33 PM SENT