On August 02, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Rhodes, Vashone,
and
Exclusive Nationwide Delivery, Inc,
Gomez, James,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
9/28/2022 10:34 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS C0., TEXAS
Rhonda Burks DEPUTY
CAUSE NO. DC-19-10926
VASHONE RHODES; § IN THE DISTRICT COURT OF
§
Plaintiff, §
§
VS. § DALLAS COUNTY, TEXAS
§
JAMES GOMEZ; AND EXCLUSIVE §
NATIONWIDE DELIVERY, INC.; §
§
Defendants. § 1607” JUDICIAL DISTRICT
JOINT MOTION FOR CONTINUANCE OF THE OCTOBER 03, 2022 TRIAL DATE
Plaintiff Vashone Rhodes and Defendants James Gomez and Exclusive
Nationwide Delivery, Inc. file this Joint Motion for Continuance of the Monday, October
03. 2022 Trial Date and show the following.
I.
This suit was filed on August 02, 2019 for injuries sustained by Plaintiff in a motor
vehicle collision that occurred on November 27, 2018. This case is set forjury trial on
October 03, 2022.
ll.
The parties request a continuance because they were unable to settle this case
at mediation and more time is needed for a second mediation. Additionally, the parties
are pending a ruling from the Court on Defendant Exclusive Nationwide Delivery, lnc.’s
Traditional Motion for Summary Judgment and Motion to Reconsider, which was heard
on September 22, 2022. The parties request a continuance of the trial date until January
09, 2023.
Ill.
This request for continuance is not for delay only. but that justice may be done.
WHEREFORE, the parties request that the Court continue this case until January
09, 2023.
JOINT MOTION FOR CONTINUANCE OF THE OCTOBER 03, 2022 TRIAL DATE — Page 1
Respectfully submitted,
WITHERITE LAW GROUP, PLLC
BY: /S/ V. Paige Eldridge
V. PAIGE ELDRIDGE
State Bar No. 24096747
paigeeldridge@witheritelaw.com
SHELLY GRECO
State Bar No. 24008168
shelly.greco@witheritelaw.com
10440 N. Central Expressway
Suite 400
Dallas. TX 75231—2228
214/378-6665
214/378-6670 (fax)
ATTORNEYS FOR PLAINTIFF
& GRAIN, LLP
WALTERSWO
BY:
RANDA GMTERS
State," r No. 20819480
ran .walters wbclawfirm.com
NADINE K. WEATHERALL
State Bar No. 24073060
nadine.weatherall wbclawfirm.com
Meadow Park Tower, 15th Floor
10440 North Central Expressway
Dallas. TX 75231
(214) 749-4805
(214) 760~1670(fax)
JOINT MOTION FOR CONTINUANCE OF THE OCTOBER 03, 2022 TRIAL DATE - Page 2
THE LECRONE LAW FIRM, P.C.
BY:
JOHN W. BREEZE
State Bar No. 00796248
john@lecronelaw.com
ADAM B. LECRONE
State Bar No.00786447
adam@lecronelaw.com
Wall Street Plaza
123 N. Crockett Street, Suite 200
Sherman. TX 75090
(903) 813-1900
(903) 813-1944(fax)
JOINT MOTION FOR CONTINUANCE OF THE OCTOBER 03, 2022 TRIAL DATE - 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.
Alexa Thompson on behalf of Paige Eldridge
Bar No. 24096747
alexa.thompson@witheritelaw.com
Envelope ID: 68687139
Status as of 9/28/2022 10:37 AM CST
Associated Case Party: VASHONE RHODES
Name BarNumber Email TimestampSubmitted Status
Amy Witherite 788698 amy.witherite@witheritelaw.com 9/28/2022 10:34:22 AM SENT
Shelly Tomlin Greco 24008168 shelly.greco@witheritelaw.com 9/28/2022 10:34:22 AM SENT
Paige Eldridge paige.eldridge@ewlawyers.com 9/28/2022 10:34:22 AM SENT
Paige Eldridge paige.eldridge@witheritelaw.com 9/28/2022 10:34:22 AM 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.
Alexa Thompson on behalf of Paige Eldridge
Bar No. 24096747
alexa.thompson@witheritelaw.com
Envelope ID: 68687139
Status as of 9/28/2022 10:37 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
V. Paige Eldridge paige.eldridge@witheritelaw.com 9/28/2022 10:34:22 AM SENT
Craig Laird PCL@LA|RD.LAWYER 9/28/2022 10:34:22 AM SENT
PAIGE VELDRIDGE paiqe.eldridqe@ewlawyers.com 9/28/2022 10:34:22 AM ERROR
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.
Alexa Thompson on behalf of Paige Eldridge
Bar No. 24096747
alexa.thompson@witheritelaw.com
Envelope ID: 68687139
Status as of 9/28/2022 10:37 AM CST
Associated Case Party: EXCLUSIVE NATIONWIDE DELIVERY, INC
Name BarNumber Email TimestampSubmitted Status
Randall GWalters waltersedocsnotifications@wbclawfirm.com 9/28/2022 10:34:22 AM SENT
Nadine K Weatherall nadine.weatherall@wbclawfirm.com 9/28/2022 10:34:22 AM SENT
Randall GWalters randy.walters@wbclawfirm.com 9/28/2022 10:34:22 AM 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.
Alexa Thompson on behalf of Paige Eldridge
Bar No. 24096747
alexa.thompson@witheritelaw.com
Envelope ID: 68687139
Status as of 9/28/2022 10:37 AM CST
Associated Case Party: JAMES GOMEZ
Name BarNumber Email TimestampSubmitted Status
Adam LeCrone eservice@lecronelaw.com 9/28/2022 10:34:22 AM SENT
Document Filed Date
September 28, 2022
Case Filing Date
August 02, 2019
Category
MOTOR VEHICLE ACCIDENT
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED 9/28/2022 10:34 AM FELICIA PITRE DISTRICT CLERK DALLAS C0., TEXAS Rhonda Burks DEPUTY CAUSE NO. DC-19-10926 VASHONE RHODES; § IN THE DISTRICT COURT OF § Plaintiff, § § VS. § DALLAS COUNTY, TEXAS § JAMES GOMEZ; AND EXCLUSIVE § NATIONWIDE DELIVERY, INC.; § § Defendants. § 1607” JUDICIAL DISTRICT JOINT MOTION FOR CONTINUANCE OF THE OCTOBER 03, 2022 TRIAL DATE Plaintiff Vashone Rhodes and Defendants James Gomez and Exclusive Nationwide Delivery, Inc. file this Joint Motion for Continuance of the Monday, October 03. 2022 Trial Date and show the following. I. This suit was filed on August 02, 2019 for injuries sustained by Plaintiff in a motor vehicle collision that occurred on November 27, 2018. This case is set forjury trial on October 03, 2022. ll. The parties request a continuance because they were unable to settle this case at mediation and more time is needed for a second mediation. Additionally, the parties are pending a ruling from the Court on Defendant Exclusive Nationwide Delivery, lnc.’s Traditional Motion for Summary Judgment and Motion to Reconsider, which was heard on September 22, 2022. The parties request a continuance of the trial date until January 09, 2023. Ill. This request for continuance is not for delay only. but that justice may be done. WHEREFORE, the parties request that the Court continue this case until January 09, 2023. JOINT MOTION FOR CONTINUANCE OF THE OCTOBER 03, 2022 TRIAL DATE — Page 1 Respectfully submitted, WITHERITE LAW GROUP, PLLC BY: /S/ V. Paige Eldridge V. PAIGE ELDRIDGE State Bar No. 24096747 paigeeldridge@witheritelaw.com SHELLY GRECO State Bar No. 24008168 shelly.greco@witheritelaw.com 10440 N. Central Expressway Suite 400 Dallas. TX 75231—2228 214/378-6665 214/378-6670 (fax) ATTORNEYS FOR PLAINTIFF & GRAIN, LLP WALTERSWO BY: RANDA GMTERS State," r No. 20819480 ran .walters wbclawfirm.com NADINE K. WEATHERALL State Bar No. 24073060 nadine.weatherall wbclawfirm.com Meadow Park Tower, 15th Floor 10440 North Central Expressway Dallas. TX 75231 (214) 749-4805 (214) 760~1670(fax) JOINT MOTION FOR CONTINUANCE OF THE OCTOBER 03, 2022 TRIAL DATE - Page 2 THE LECRONE LAW FIRM, P.C. BY: JOHN W. BREEZE State Bar No. 00796248 john@lecronelaw.com ADAM B. LECRONE State Bar No.00786447 adam@lecronelaw.com Wall Street Plaza 123 N. Crockett Street, Suite 200 Sherman. TX 75090 (903) 813-1900 (903) 813-1944(fax) JOINT MOTION FOR CONTINUANCE OF THE OCTOBER 03, 2022 TRIAL DATE - 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. Alexa Thompson on behalf of Paige Eldridge Bar No. 24096747 alexa.thompson@witheritelaw.com Envelope ID: 68687139 Status as of 9/28/2022 10:37 AM CST Associated Case Party: VASHONE RHODES Name BarNumber Email TimestampSubmitted Status Amy Witherite 788698 amy.witherite@witheritelaw.com 9/28/2022 10:34:22 AM SENT Shelly Tomlin Greco 24008168 shelly.greco@witheritelaw.com 9/28/2022 10:34:22 AM SENT Paige Eldridge paige.eldridge@ewlawyers.com 9/28/2022 10:34:22 AM SENT Paige Eldridge paige.eldridge@witheritelaw.com 9/28/2022 10:34:22 AM 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. Alexa Thompson on behalf of Paige Eldridge Bar No. 24096747 alexa.thompson@witheritelaw.com Envelope ID: 68687139 Status as of 9/28/2022 10:37 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status V. Paige Eldridge paige.eldridge@witheritelaw.com 9/28/2022 10:34:22 AM SENT Craig Laird PCL@LA|RD.LAWYER 9/28/2022 10:34:22 AM SENT PAIGE VELDRIDGE paiqe.eldridqe@ewlawyers.com 9/28/2022 10:34:22 AM ERROR 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. Alexa Thompson on behalf of Paige Eldridge Bar No. 24096747 alexa.thompson@witheritelaw.com Envelope ID: 68687139 Status as of 9/28/2022 10:37 AM CST Associated Case Party: EXCLUSIVE NATIONWIDE DELIVERY, INC Name BarNumber Email TimestampSubmitted Status Randall GWalters waltersedocsnotifications@wbclawfirm.com 9/28/2022 10:34:22 AM SENT Nadine K Weatherall nadine.weatherall@wbclawfirm.com 9/28/2022 10:34:22 AM SENT Randall GWalters randy.walters@wbclawfirm.com 9/28/2022 10:34:22 AM 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. Alexa Thompson on behalf of Paige Eldridge Bar No. 24096747 alexa.thompson@witheritelaw.com Envelope ID: 68687139 Status as of 9/28/2022 10:37 AM CST Associated Case Party: JAMES GOMEZ Name BarNumber Email TimestampSubmitted Status Adam LeCrone eservice@lecronelaw.com 9/28/2022 10:34:22 AM SENT