On May 26, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Dietz, Chad,
and
Bold Stroke Studios,
Segura, Josue,
Velazquez, Antonio,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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FILED
3/31/2021 8:04 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Jeremy Jones DEPUTY
CAUSE NO. DC-20-07281
CHAD DIETZ, § IN THE DISTRICT COURT
Plaintiff, §
§
v. § 134TH JUDICIAL DISTRICT
§
JOSUE SEGURA, BOLD STROKE §
STUDIOS, and ANTONIO VELAZQUEZ, §
Defendants. § DALLAS COUNTY, TEXAS
MOTION FOR CONTINUANCE
COMES NOW Chad Dietz (hereinafter “Plaintiff”) and les this Motion for Continuance
and would respectfully Show the Court as follows:
1. This is Plaintiff’ s rst Motionfor Continuance in this matter.
2. Due to the COVID—19 pandemic, the Supreme Court Of Texas ordered that courts cannot
hold in-person trials. In particular, the Texas Supreme Court’s 33rd Emergency Order,
dated January l4, 202 1, provides that a District Court must not conduct an in-person jury
proceeding without meeting various pre-requisites including the submission of a plan for
conducting jury proceedings consistent with Guidance issued by the Ofce of Court
Administration.
3. Additionally, discovery is ongoing in this matter, and further investigation in written and
oral discovery is necessary.
4. Plaintiff would state that this Motionfor Continuance is not sought for delay only, but so
that justice may be achieved.
PRAYER
WHEREFORE Plaintiff respectfully requests that this Motion for Continuance be in all
things granted, that the present Trial setting be continued for approximately 90 days after the
present trial setting of April 12, 2021, and for such further relief that plaintiff may be entitled.
Respectfully submitted,
SNELLINGS LAW, P.L.L.C.
Motionfor Continuance Page l of 3
/s/R0ci0 Gosewehr Hernandez
Rocio Gosewehr Hernandez
State Bar No. 24067660
Email: Rocio@SnellingsInjuryLaw.com
Scott Snellings
Texas Bar No. 24046878
Email: Scott@SnellingsInjuryLaw.com
5750 Genesis Court, Suite 205
Frisco, Texas 75034
Tel. (214) 387-0387
Fax. (469) 2 l 7-8347
E-Service Email: Service@SnellingslnjuryLaw.com
ATTORNEYS FOR PLAINTIFF
Motionfor Continuance Page 2 of 3
CERTIFICATE OF CONFERENCE
This is to certify That the undersigned attorney conferred in good faith with all counsel of
record in this matter. Counsel for Defendants Josue Segura and Bold Stroke Studios is
OPPOSED to the motion.
/s/ Rocio Gosewehr Hernandez
ROCIO GOSEWEHR HERNANDEZ
CERTIFICATE OF SERVICE
This is to certify that on this day ofMarch 3 1, 202 1 , a true and correct copy ofthe foregoing
was transmitted, via E-Service, to counsel of record as follows:
VIA E-FILE
ALEMAN LAW FIRM, P.C.
4054 McKinney Ave., Ste. 3 l 0
Dallas, Texas 75204
(214) 373 -7774 (Telephone)
(214) 764-4035 (Facsimile)
Sergio@sergioealeman.com
/s/ Rocio Gosewehr Hernandez
ROCIO GOSEWEHR HERNANDEZ
Motionfor Continuance Page 3 of 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.
Katy Strandlien on behalf of Rocio Gosewehr Hernandez
Bar No. 24067660
Katy@snellingsinjurylaw.com
Envelope ID: 51995640
Status as of 3/31/2021 12:28 PM CST
Associated Case Party: CHAD DIETZ
Name BarNumber Email TimestampSubmitted Status
Rocio GosewehrHernandez Rocio@SnellingslnjuryLaw.com 3/31/2021 8:04:24 AM SENT
Snellings Service Service@Snellingsinjurylaw.com 3/31/2021 8:04:24 AM SENT
Katy Strandlien katy@snellingsinjurylaw.com 3/31/2021 8:04:24 AM SENT
Associated Case Party: JOSUE SEGURA
Name BarNumber Email TimestampSubmitted Status
Josue Segura hakishio@outlook.com 3/31/2021 8:04:24 AM SENT
Associated Case Party: BOLD STROKE STUDIOS
Name BarNumber Email TimestampSubmitted Status
Josue Segura hakishio@outlook.com 3/31/2021 8:04:24 AM SENT
Associated Case Party: ANTONIO VELAZQUEZ
Name BarNumber Email TimestampSubmitted Status
Antonio Velazquez ANT0698@HOTMAIL.COM 3/31/2021 8:04:24 AM SENT
Case Contacts
Name
Sergio EAleman
Ronald Paul Wright
Francine Ly
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.
Katy Strandlien on behalf of Rocio Gosewehr Hernandez
Bar No. 24067660
Katy@snellingsinjurylaw.com
Envelope ID: 51995640
Status as of 3/31/2021 12:28 PM CST
Case Contacts
Pete Weise pete@sergioealeman.com 3/31/2021 8:04:24 AM SENT
Document Filed Date
March 31, 2021
Case Filing Date
May 26, 2020
Category
MOTOR VEHICLE ACCIDENT
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FILED 3/31/2021 8:04 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Jeremy Jones DEPUTY CAUSE NO. DC-20-07281 CHAD DIETZ, § IN THE DISTRICT COURT Plaintiff, § § v. § 134TH JUDICIAL DISTRICT § JOSUE SEGURA, BOLD STROKE § STUDIOS, and ANTONIO VELAZQUEZ, § Defendants. § DALLAS COUNTY, TEXAS MOTION FOR CONTINUANCE COMES NOW Chad Dietz (hereinafter “Plaintiff”) and les this Motion for Continuance and would respectfully Show the Court as follows: 1. This is Plaintiff’ s rst Motionfor Continuance in this matter. 2. Due to the COVID—19 pandemic, the Supreme Court Of Texas ordered that courts cannot hold in-person trials. In particular, the Texas Supreme Court’s 33rd Emergency Order, dated January l4, 202 1, provides that a District Court must not conduct an in-person jury proceeding without meeting various pre-requisites including the submission of a plan for conducting jury proceedings consistent with Guidance issued by the Ofce of Court Administration. 3. Additionally, discovery is ongoing in this matter, and further investigation in written and oral discovery is necessary. 4. Plaintiff would state that this Motionfor Continuance is not sought for delay only, but so that justice may be achieved. PRAYER WHEREFORE Plaintiff respectfully requests that this Motion for Continuance be in all things granted, that the present Trial setting be continued for approximately 90 days after the present trial setting of April 12, 2021, and for such further relief that plaintiff may be entitled. Respectfully submitted, SNELLINGS LAW, P.L.L.C. Motionfor Continuance Page l of 3 /s/R0ci0 Gosewehr Hernandez Rocio Gosewehr Hernandez State Bar No. 24067660 Email: Rocio@SnellingsInjuryLaw.com Scott Snellings Texas Bar No. 24046878 Email: Scott@SnellingsInjuryLaw.com 5750 Genesis Court, Suite 205 Frisco, Texas 75034 Tel. (214) 387-0387 Fax. (469) 2 l 7-8347 E-Service Email: Service@SnellingslnjuryLaw.com ATTORNEYS FOR PLAINTIFF Motionfor Continuance Page 2 of 3 CERTIFICATE OF CONFERENCE This is to certify That the undersigned attorney conferred in good faith with all counsel of record in this matter. Counsel for Defendants Josue Segura and Bold Stroke Studios is OPPOSED to the motion. /s/ Rocio Gosewehr Hernandez ROCIO GOSEWEHR HERNANDEZ CERTIFICATE OF SERVICE This is to certify that on this day ofMarch 3 1, 202 1 , a true and correct copy ofthe foregoing was transmitted, via E-Service, to counsel of record as follows: VIA E-FILE ALEMAN LAW FIRM, P.C. 4054 McKinney Ave., Ste. 3 l 0 Dallas, Texas 75204 (214) 373 -7774 (Telephone) (214) 764-4035 (Facsimile) Sergio@sergioealeman.com /s/ Rocio Gosewehr Hernandez ROCIO GOSEWEHR HERNANDEZ Motionfor Continuance Page 3 of 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. Katy Strandlien on behalf of Rocio Gosewehr Hernandez Bar No. 24067660 Katy@snellingsinjurylaw.com Envelope ID: 51995640 Status as of 3/31/2021 12:28 PM CST Associated Case Party: CHAD DIETZ Name BarNumber Email TimestampSubmitted Status Rocio GosewehrHernandez Rocio@SnellingslnjuryLaw.com 3/31/2021 8:04:24 AM SENT Snellings Service Service@Snellingsinjurylaw.com 3/31/2021 8:04:24 AM SENT Katy Strandlien katy@snellingsinjurylaw.com 3/31/2021 8:04:24 AM SENT Associated Case Party: JOSUE SEGURA Name BarNumber Email TimestampSubmitted Status Josue Segura hakishio@outlook.com 3/31/2021 8:04:24 AM SENT Associated Case Party: BOLD STROKE STUDIOS Name BarNumber Email TimestampSubmitted Status Josue Segura hakishio@outlook.com 3/31/2021 8:04:24 AM SENT Associated Case Party: ANTONIO VELAZQUEZ Name BarNumber Email TimestampSubmitted Status Antonio Velazquez ANT0698@HOTMAIL.COM 3/31/2021 8:04:24 AM SENT Case Contacts Name Sergio EAleman Ronald Paul Wright Francine Ly 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. Katy Strandlien on behalf of Rocio Gosewehr Hernandez Bar No. 24067660 Katy@snellingsinjurylaw.com Envelope ID: 51995640 Status as of 3/31/2021 12:28 PM CST Case Contacts Pete Weise pete@sergioealeman.com 3/31/2021 8:04:24 AM SENT