On August 17, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Downie-Fraser, Nicole E.,
and
Sainz, Valeria,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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FILED
DALLAS COUNTY
1/4/2019 8:56 AM
FELICIA PITRE
DISTRICT CLERK
Martin Reyes
CAUSE NO. DC- 1 7- 1 0220
NICOLE E. DOWNIE-FRASER, IN THE DISTRICT COURT
Plaintiff(s),
VS. 95TH JUDICIAL DISTRICT
VALERIA SAINZ,
Defendant(s). DALLAS COUNTY, TEXAS
UNOPPOSED MOTION FOR CONTINUANCE
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES, VALERIA SAINZ, Defendant, herein, and files this Unopposed Motion
for Continuance and as grounds therefore would respectfully show the Court as follows:
I.
Defendant, VALERIA SAINZ, requests that this Court grant them a continuance from the
trial setting 0n January 14, 2019.
II.
Defendant Valeria Sainz’ mother is in her final stages of life, and Ms. Sainz needs t0 travel
to Mexico to be With her for the remainder of her life. We respectfully request 90 days in order for
Ms. Sainz to be With her family during this time.
Therefore, in the interest ofjustice and not for the purpose 0f delay, this Defendant duly
moves the Court for a continuance and asks that the case be set for trial 0n its merits for a time
convenient to the Court and parties.
WHEREFORE, PREMISES CONSIDERED, Defendant prays that this Motion for
Continuance be granted, and for such other and further relief t0 Which Defendant may show
himself/herselfjustly entitled.
Respectfully submitted,
SUSAN L. FLORENCE & ASSOCIATES
KAVITA BHALLA
TBN: 24080789
1201 Elm St., 5050
Suite
Dallas, TX 75270-2104
DallasLegal@allstate.com
(214) 659-4352
(877) 678-4763 (fax)
ATTORNEY FOR DEFENDANT(S)
VALERIA SAINZ
CERTIFICATE OF CONFERENCE
A conference was held 0n January 3, 2019 With Cameron Dean, attorney for Plaintiff(s),
regarding this Motion. He is unopposed. Therefore, this motion is presented for review and
signature.
KAVITA BHALLA
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy 0f the foregoing has been served in compliance
with Rules 21 and 21a of the Texas Rules 0f Civil Procedure on the 4th day 0f January 2019, to:
Attorney for Plaintiff Downie-Fraser
Cameron Dean, Esquire
Ben Abbott & Associates, PLLC
1934 Pendleton Dr
Garland TX 75041
KAVITA BHALLA
STATE OF TEXAS §
§
COUNTY 0F DALLAS §
"My name is Kavita Bhalla. I am over the age 0f 21 and fully competent t0 make this
Affidavit.
"I am an attorney With SUSAN L. FLORENCE & ASSOCIATES, attorney of record for
the Defendant, VALERIA SAINZ, in this cause number DC- 1 7- 1 0220. Ihave personal knowledge
0f all statements in the above Unopposed Motion for Continuance, and they are true and correct."
KAVITA BHALLA
STATE OF TEXAS
COUNTY OF DALLAS
On this 4th day of January 2019, before me personally appeared Kavita Bhalla, to me to
be the person who executed the foregoing instrument, and acknowledged that he/she executed
the same as his/her free act and deed.
Notary Pub State of Texas
Notary's Printed Name:
My Commission Expi
Document Filed Date
January 04, 2019
Case Filing Date
August 17, 2017
Category
MOTOR VEHICLE ACCIDENT
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FILED DALLAS COUNTY 1/4/2019 8:56 AM FELICIA PITRE DISTRICT CLERK Martin Reyes CAUSE NO. DC- 1 7- 1 0220 NICOLE E. DOWNIE-FRASER, IN THE DISTRICT COURT Plaintiff(s), VS. 95TH JUDICIAL DISTRICT VALERIA SAINZ, Defendant(s). DALLAS COUNTY, TEXAS UNOPPOSED MOTION FOR CONTINUANCE TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES, VALERIA SAINZ, Defendant, herein, and files this Unopposed Motion for Continuance and as grounds therefore would respectfully show the Court as follows: I. Defendant, VALERIA SAINZ, requests that this Court grant them a continuance from the trial setting 0n January 14, 2019. II. Defendant Valeria Sainz’ mother is in her final stages of life, and Ms. Sainz needs t0 travel to Mexico to be With her for the remainder of her life. We respectfully request 90 days in order for Ms. Sainz to be With her family during this time. Therefore, in the interest ofjustice and not for the purpose 0f delay, this Defendant duly moves the Court for a continuance and asks that the case be set for trial 0n its merits for a time convenient to the Court and parties. WHEREFORE, PREMISES CONSIDERED, Defendant prays that this Motion for Continuance be granted, and for such other and further relief t0 Which Defendant may show himself/herselfjustly entitled. Respectfully submitted, SUSAN L. FLORENCE & ASSOCIATES KAVITA BHALLA TBN: 24080789 1201 Elm St., 5050 Suite Dallas, TX 75270-2104 DallasLegal@allstate.com (214) 659-4352 (877) 678-4763 (fax) ATTORNEY FOR DEFENDANT(S) VALERIA SAINZ CERTIFICATE OF CONFERENCE A conference was held 0n January 3, 2019 With Cameron Dean, attorney for Plaintiff(s), regarding this Motion. He is unopposed. Therefore, this motion is presented for review and signature. KAVITA BHALLA CERTIFICATE OF SERVICE I hereby certify that a true and correct copy 0f the foregoing has been served in compliance with Rules 21 and 21a of the Texas Rules 0f Civil Procedure on the 4th day 0f January 2019, to: Attorney for Plaintiff Downie-Fraser Cameron Dean, Esquire Ben Abbott & Associates, PLLC 1934 Pendleton Dr Garland TX 75041 KAVITA BHALLA STATE OF TEXAS § § COUNTY 0F DALLAS § "My name is Kavita Bhalla. I am over the age 0f 21 and fully competent t0 make this Affidavit. "I am an attorney With SUSAN L. FLORENCE & ASSOCIATES, attorney of record for the Defendant, VALERIA SAINZ, in this cause number DC- 1 7- 1 0220. Ihave personal knowledge 0f all statements in the above Unopposed Motion for Continuance, and they are true and correct." KAVITA BHALLA STATE OF TEXAS COUNTY OF DALLAS On this 4th day of January 2019, before me personally appeared Kavita Bhalla, to me to be the person who executed the foregoing instrument, and acknowledged that he/she executed the same as his/her free act and deed. Notary Pub State of Texas Notary's Printed Name: My Commission Expi