On September 27, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Mosco, Rose,
and
Miller, Sandra,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
8/31/2022 5:25 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Marissa Gomez DEPUTY
CAUSE NO. DC-21-14355
ROSE MOSCO, IN THE DISTRICT COURT
Plaintiff,
v. 134”" JUDICIAL DISTRICT
SANDRA MILLER,
Defendant DALLAS COUNTY, TEXAS
PLAINTIFF’S MOTION FOR CONTINUANCE
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, ROSE MOSCO, Plaintiff, and moves the Court to continue the
trial in the above-entitled and numbered cause, heretofore set for September 1, 2022,
for at least 90 days. The Plaintiff seeks this continuance because Plaintiff is unable to
attend the trial setting as called on Wednesday, September 1, 2022. Plaintiff is
currently scheduled for a cardiologist appointment on September 1, 2022 and this
appointment cannot be missed nor rescheduled. Plaintiff informed her attorney’s office
of this on Wednesday, September 1, 2022. Plaintiff will not be available to attend the
current trial setting due to this reason and seeks a short continuance so that she may
be able to be present at her trial setting. This request for continuance is not for delay
only, but thatjustice may be done.
PRAYER
WHEREFORE, the Plaintiff requests that the Court continue this case for at least
90 days.
Respectfully submitted,
Ben Abbott & Associates, PLLC
1934 Pendleton Drive
Garland, TX 75041
(972) 263-5555
(817) 263-5555
(972) 682-7586 Facsimile
eService@benabbott.com
O. IIo Guerrero
.
State Bar No.24126397
ATTORNEY FOR PLAINTIFF(S)
PLAINTIFF’S MOTION FOR CONTINUANCE PAGE 1
CERTIFICATE OF SERVICE
This is to certify that the foregoing Plaintiff’s Motion for Continuance has been
forwarded to Counsel for the Defendant on this 3i“ day of August, 202, as follows:
VIA ESERVICE:
Mark A. Teague
The LeCrone Law Firm, PC
123 North Crockett St, Suite 200
Sherman, TX 75090
Rogelio Guerrero
CERTIFICATE OF CONFERENCE
l, hereby certify, that Defense Counsel:
(_) is agreed to this motion
(_) is opposed to this motion
(_) is unopposed to this motion
(L) was unable to confer with Defense Counsel regarding their position on this
motion.
Rogelig Guerrero
PLAINTIFF’S MOTION FOR CONTINUANCE PAGE 2
VERIFICATION
STATE OF TEXAS §
§
COUNTY OF DALLAS §
BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally
appeared Rogelio Guerrero, who being by me first duly sworn did on his/her oath
depose and say that he/she is a person duly qualified and authorized in all respects to
make this Affidavit; that he/she has read the above and foregoing Verified Motion for
Continuance; that the facts in it are within his/her personal knowledge, and are true and
correct.
Rog: eIE Guerrero
SWORN TO AND SUBSCRIBED before me by Rogelio Guerrero on the day
of August, 20g.
a
xii-L .IIVIII. Leéjfix’fi
NoTARY PUBLIC in and for
the STATE 0F TEXAS
1|- + Hams-limo
I
I“?! III-lin-
'_- In. .ud H W Eli-ii
PLAINTIFF’S MOTION FOR CONTINUANCE PAGE 3
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.
ANTHONY MATA on behalf of Rogelio Guerrero
Bar No. 24126397
anthony.mata@benabbott.com
Envelope ID: 67865330
Status as of 9/1/2022 8:32 AM CST
Associated Case Party: SANDRA MILLER
Name BarNumber Email TimestampSubmitted Status
Mark A.Teague eservice@lecronelaw.com 8/31/2022 5:25:55 PM SENT
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.
ANTHONY MATA on behalf of Rogelio Guerrero
Bar No. 24126397
anthony.mata@benabbott.com
Envelope ID: 67865330
Status as of 9/1/2022 8:32 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Francine Ly fly@dallascourts.org 8/31/2022 5:25:55 PM SENT
Document Filed Date
August 31, 2022
Case Filing Date
September 27, 2021
Category
MOTOR VEHICLE ACCIDENT
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FILED 8/31/2022 5:25 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Marissa Gomez DEPUTY CAUSE NO. DC-21-14355 ROSE MOSCO, IN THE DISTRICT COURT Plaintiff, v. 134”" JUDICIAL DISTRICT SANDRA MILLER, Defendant DALLAS COUNTY, TEXAS PLAINTIFF’S MOTION FOR CONTINUANCE TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, ROSE MOSCO, Plaintiff, and moves the Court to continue the trial in the above-entitled and numbered cause, heretofore set for September 1, 2022, for at least 90 days. The Plaintiff seeks this continuance because Plaintiff is unable to attend the trial setting as called on Wednesday, September 1, 2022. Plaintiff is currently scheduled for a cardiologist appointment on September 1, 2022 and this appointment cannot be missed nor rescheduled. Plaintiff informed her attorney’s office of this on Wednesday, September 1, 2022. Plaintiff will not be available to attend the current trial setting due to this reason and seeks a short continuance so that she may be able to be present at her trial setting. This request for continuance is not for delay only, but thatjustice may be done. PRAYER WHEREFORE, the Plaintiff requests that the Court continue this case for at least 90 days. Respectfully submitted, Ben Abbott & Associates, PLLC 1934 Pendleton Drive Garland, TX 75041 (972) 263-5555 (817) 263-5555 (972) 682-7586 Facsimile eService@benabbott.com O. IIo Guerrero . State Bar No.24126397 ATTORNEY FOR PLAINTIFF(S) PLAINTIFF’S MOTION FOR CONTINUANCE PAGE 1 CERTIFICATE OF SERVICE This is to certify that the foregoing Plaintiff’s Motion for Continuance has been forwarded to Counsel for the Defendant on this 3i“ day of August, 202, as follows: VIA ESERVICE: Mark A. Teague The LeCrone Law Firm, PC 123 North Crockett St, Suite 200 Sherman, TX 75090 Rogelio Guerrero CERTIFICATE OF CONFERENCE l, hereby certify, that Defense Counsel: (_) is agreed to this motion (_) is opposed to this motion (_) is unopposed to this motion (L) was unable to confer with Defense Counsel regarding their position on this motion. Rogelig Guerrero PLAINTIFF’S MOTION FOR CONTINUANCE PAGE 2 VERIFICATION STATE OF TEXAS § § COUNTY OF DALLAS § BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally appeared Rogelio Guerrero, who being by me first duly sworn did on his/her oath depose and say that he/she is a person duly qualified and authorized in all respects to make this Affidavit; that he/she has read the above and foregoing Verified Motion for Continuance; that the facts in it are within his/her personal knowledge, and are true and correct. Rog: eIE Guerrero SWORN TO AND SUBSCRIBED before me by Rogelio Guerrero on the day of August, 20g. a xii-L .IIVIII. Leéjfix’fi NoTARY PUBLIC in and for the STATE 0F TEXAS 1|- + Hams-limo I I“?! III-lin- '_- In. .ud H W Eli-ii PLAINTIFF’S MOTION FOR CONTINUANCE PAGE 3 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. ANTHONY MATA on behalf of Rogelio Guerrero Bar No. 24126397 anthony.mata@benabbott.com Envelope ID: 67865330 Status as of 9/1/2022 8:32 AM CST Associated Case Party: SANDRA MILLER Name BarNumber Email TimestampSubmitted Status Mark A.Teague eservice@lecronelaw.com 8/31/2022 5:25:55 PM SENT 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. ANTHONY MATA on behalf of Rogelio Guerrero Bar No. 24126397 anthony.mata@benabbott.com Envelope ID: 67865330 Status as of 9/1/2022 8:32 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Francine Ly fly@dallascourts.org 8/31/2022 5:25:55 PM SENT