On May 02, 2023 a
MOTION TO BIFURCATE - MOTION - BIFURCATE
was filed
involving a dispute between
Donaldson, Diana,
Petty-Alfaro, Marrieann,
and
Southern Star Inc.,
Wright, Ledarius,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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FILED
5/22/2023 3:25 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Steve Brashear DEPUTY
CAUSE NO. DC-23-05787
DIANA DONALDSON AND § IN THE DISTRICT COURT
MARRIEANN PETTY-ALFARO, §
PLAINTIFFS, §
§
VS. § 44TH DISTRICT
§
LEDARIUS WRIGHT AND
SOUTHERN STAR g
INCORPORATED, § DALLAS COUNTY, TEXAS
DEFENDANTS. §
DEFENDANTS’ LEDARIUS WRIGHT AND SOUTHERN STAR INCORPORATED’S
MOTION TO BIFURCATE
TO THE HONORABLE JUDGE OF SAID COURT:
COME NOW, Ladarius Wright and Southern Star Incorporated, Defendants in the above
entitled and numbered cause, and files this Motion to Bifilrcate and in support would respectfully
show the Court as follows:
1.
Pursuant to Texas Civil Practices and Remedies Code 72.052, Defendants would move that
this trial be bifurcated as set forth in Chapter 72. This Motion is being filed within 120 days of
Defendants’ Original Answer which was filed on May 18, 2023.
WHEREFORE, PREMISES CONSIDERED, Defendants Ledarius Wright and Southern Star
Incorporated pray that this Motion be granted by Court as set forth by statute and that Defendants
Ledarius Wright and Southern Star Incorporated be discharged with its costs and that they have such
other and further relief to which they may be justly entitled at law or in equity.
Respectfully Submitted,
AYIK & ASSOCIATES
/s/ Shelly S Jock
SHELLY S. JOCK
Texas Bar No. 00794026
E-Mail: sjock@travelers.com
Mailing Address:
DEFENDANTS LEDARIUS WRIGHT AND SOUTHERN STAR INCORPoRATEDS MoTION To BITIRCATE PAGE 1
P.O. Box 64093
St. Paul, MN 55164-0093
Physical Address
1301 E. Collins Blvd., Suite 290
Richardson, Texas 75081
Direct Telephone: 214-200-2292
Main Telephone: 214-570-6300
ATTORNEYS FOR DEFENDAN TS
LEDARIUS WRIGHT AND SOUTHERN STAR
INCORPORATED
CERTIFICATE OF SERVICE
This is to certify that, on this the 22nd day of May, 2023, a true and correct copy of the
foregoing document was forwarded to all counsel of record as follows:
Richard B. Waterhouse Hand Delivery
The Law Offices of Tim O'Hare Facsimile
1038 S. Elm Street Certified Mail, Return Receipt Requested
Carrollton, TX 75006 Receipted Commercial Delivery
Regular U.S. Mail
Attorney for Plaintiffl x E-service
Diana Donaldson and Marrieann Petty-
Alfaro
/s/ Shelly S. Jock
Shelly S. Jock
DEFENDANT S LEDARIU S WRIGHT AND SOUTHERN STAR INCORPORATED’S MOTION TO BEIRCATE 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.
Donna Pitek on behalf of Shelly Jock
Bar No. 794026
dpitek@travelers.com
Envelope ID: 75877748
Filing Code Description: Motion - Bifurcate
Filing Description:
Status as of 5/24/2023 2:43 PM CST
Associated Case Party: DIANA DONALDSON
Name BarNumber Email TimestampSubmitted Status
Richard Brian Waterhouse 788624 rick@oharelawfirm.com 5/22/2023 3:25:56 PM SENT
Rileigh C.Hanson rileigh@oharelawfirm.com 5/22/2023 3:25:56 PM SENT
David B.Koch david@oharelawfirm.com 5/22/2023 3:25:56 PM SENT
Nicholas Chrestopoulos nicholas@oharelawfirm.com 5/22/2023 3:25:56 PM SENT
Associated Case Party: SOUTHERN STAR INC.
Name BarNumber Email Timestam pSubmitted Status
Shelly S.Jock sjock@travelers.com 5/22/2023 3:25:56 PM SENT
Document Filed Date
May 22, 2023
Case Filing Date
May 02, 2023
Category
MOTOR VEHICLE ACCIDENT
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FILED 5/22/2023 3:25 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Steve Brashear DEPUTY CAUSE NO. DC-23-05787 DIANA DONALDSON AND § IN THE DISTRICT COURT MARRIEANN PETTY-ALFARO, § PLAINTIFFS, § § VS. § 44TH DISTRICT § LEDARIUS WRIGHT AND SOUTHERN STAR g INCORPORATED, § DALLAS COUNTY, TEXAS DEFENDANTS. § DEFENDANTS’ LEDARIUS WRIGHT AND SOUTHERN STAR INCORPORATED’S MOTION TO BIFURCATE TO THE HONORABLE JUDGE OF SAID COURT: COME NOW, Ladarius Wright and Southern Star Incorporated, Defendants in the above entitled and numbered cause, and files this Motion to Bifilrcate and in support would respectfully show the Court as follows: 1. Pursuant to Texas Civil Practices and Remedies Code 72.052, Defendants would move that this trial be bifurcated as set forth in Chapter 72. This Motion is being filed within 120 days of Defendants’ Original Answer which was filed on May 18, 2023. WHEREFORE, PREMISES CONSIDERED, Defendants Ledarius Wright and Southern Star Incorporated pray that this Motion be granted by Court as set forth by statute and that Defendants Ledarius Wright and Southern Star Incorporated be discharged with its costs and that they have such other and further relief to which they may be justly entitled at law or in equity. Respectfully Submitted, AYIK & ASSOCIATES /s/ Shelly S Jock SHELLY S. JOCK Texas Bar No. 00794026 E-Mail: sjock@travelers.com Mailing Address: DEFENDANTS LEDARIUS WRIGHT AND SOUTHERN STAR INCORPoRATEDS MoTION To BITIRCATE PAGE 1 P.O. Box 64093 St. Paul, MN 55164-0093 Physical Address 1301 E. Collins Blvd., Suite 290 Richardson, Texas 75081 Direct Telephone: 214-200-2292 Main Telephone: 214-570-6300 ATTORNEYS FOR DEFENDAN TS LEDARIUS WRIGHT AND SOUTHERN STAR INCORPORATED CERTIFICATE OF SERVICE This is to certify that, on this the 22nd day of May, 2023, a true and correct copy of the foregoing document was forwarded to all counsel of record as follows: Richard B. Waterhouse Hand Delivery The Law Offices of Tim O'Hare Facsimile 1038 S. Elm Street Certified Mail, Return Receipt Requested Carrollton, TX 75006 Receipted Commercial Delivery Regular U.S. Mail Attorney for Plaintiffl x E-service Diana Donaldson and Marrieann Petty- Alfaro /s/ Shelly S. Jock Shelly S. Jock DEFENDANT S LEDARIU S WRIGHT AND SOUTHERN STAR INCORPORATED’S MOTION TO BEIRCATE 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. Donna Pitek on behalf of Shelly Jock Bar No. 794026 dpitek@travelers.com Envelope ID: 75877748 Filing Code Description: Motion - Bifurcate Filing Description: Status as of 5/24/2023 2:43 PM CST Associated Case Party: DIANA DONALDSON Name BarNumber Email TimestampSubmitted Status Richard Brian Waterhouse 788624 rick@oharelawfirm.com 5/22/2023 3:25:56 PM SENT Rileigh C.Hanson rileigh@oharelawfirm.com 5/22/2023 3:25:56 PM SENT David B.Koch david@oharelawfirm.com 5/22/2023 3:25:56 PM SENT Nicholas Chrestopoulos nicholas@oharelawfirm.com 5/22/2023 3:25:56 PM SENT Associated Case Party: SOUTHERN STAR INC. Name BarNumber Email Timestam pSubmitted Status Shelly S.Jock sjock@travelers.com 5/22/2023 3:25:56 PM SENT