On October 22, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Perez, Nancy Ann,
and
Perez, Lesli Nicole,
for Parent Child Relationship - Conservatorship, Access, Support
in the District Court of Montgomery County.
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NO. 21-11-15235
IN THE MATTER OF § IN THE DISTRICT COURT
THE MARRIAGE OF §
§
GERARDO BALTIERRA §
AND § 418TH JUDICIAL DISTRICT
LESLI NICOLE PEREZ §
§
AND IN THE INTEREST OF §
GERARDO LONNIE BALTIERRA, §
A CHILD § MONTGOMERY COUNTY, TEXAS
NO. 21-10-14737
IN THE INTEREST OF § IN THE DISTRICT COURT
§
GERARDO LONNIE BALTIERRA AND § 418th JUDICIAL DISTRICT
NAYDEAN PEREZ, §
§
CHILDREN § MONTGOMERY COUNTY, TEXAS
MOTION TO CONSOLIDATE
This Motion to Consolidate the above lawsuits is brought by Nancy Perez, who shows in
support:
1. These lawsuits involve common questions of law or of fact.
2. It would serve the convenience of the Court, litigants, and counsel and would
avoid multiplicity of suits, duplication of testimony, and unnecessary expense and delay to have
these lawsuits consolidated for trial.
Nancy Perez prays that the Court grant the Motion to Consolidate and consolidate these
lawsuits under the older and lower cause number.
Respectfully submitted,
THE HARRISON FIRM, PLLC
215 Simonton
Conroe, Texas 77301
Tel: (936) 828-3898
Fax: (936) 828-3965
By:
William E. Harrison
State Bar No. 00789780
E-mail: conroeattorney@yahoo.com
Attorney for Gerardo Baltierra
Notice of Hearing
The above motion is set for hearing on December ______, 2021, at 9:00 a.m., in the 418th
District Court.
William E. Harrison
Certificate of Service
I certify that a true copy of this Motion to Consolidate was served in accordance with rule
21a of the Texas Rules of Civil Procedure on the following on December 1, 2021:
Gereado Baltierra, Pro-Se Petitioner, by electronic filing manager.
Terri Mendez, Amicus Attorney, by electronic filing manager.
William E. Harrison
Attorney for Nancy Perez
Document Filed Date
December 01, 2021
Case Filing Date
October 22, 2021
Category
Parent Child Relationship - Conservatorship, Access, Support
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NO. 21-11-15235 IN THE MATTER OF § IN THE DISTRICT COURT THE MARRIAGE OF § § GERARDO BALTIERRA § AND § 418TH JUDICIAL DISTRICT LESLI NICOLE PEREZ § § AND IN THE INTEREST OF § GERARDO LONNIE BALTIERRA, § A CHILD § MONTGOMERY COUNTY, TEXAS NO. 21-10-14737 IN THE INTEREST OF § IN THE DISTRICT COURT § GERARDO LONNIE BALTIERRA AND § 418th JUDICIAL DISTRICT NAYDEAN PEREZ, § § CHILDREN § MONTGOMERY COUNTY, TEXAS MOTION TO CONSOLIDATE This Motion to Consolidate the above lawsuits is brought by Nancy Perez, who shows in support: 1. These lawsuits involve common questions of law or of fact. 2. It would serve the convenience of the Court, litigants, and counsel and would avoid multiplicity of suits, duplication of testimony, and unnecessary expense and delay to have these lawsuits consolidated for trial. Nancy Perez prays that the Court grant the Motion to Consolidate and consolidate these lawsuits under the older and lower cause number. Respectfully submitted, THE HARRISON FIRM, PLLC 215 Simonton Conroe, Texas 77301 Tel: (936) 828-3898 Fax: (936) 828-3965 By: William E. Harrison State Bar No. 00789780 E-mail: conroeattorney@yahoo.com Attorney for Gerardo Baltierra Notice of Hearing The above motion is set for hearing on December ______, 2021, at 9:00 a.m., in the 418th District Court. William E. Harrison Certificate of Service I certify that a true copy of this Motion to Consolidate was served in accordance with rule 21a of the Texas Rules of Civil Procedure on the following on December 1, 2021: Gereado Baltierra, Pro-Se Petitioner, by electronic filing manager. Terri Mendez, Amicus Attorney, by electronic filing manager. William E. Harrison Attorney for Nancy Perez