Preview
DC-19-06300
CAUSE NO. _ _ _ __
D. ALAN MEEKER, §§ 0F
IN THE DISTRICT COURT OF
§
Plaintiff,
Plaintiff, §g
§
v.
v. §g DALLAS COUNTY, TEXAS
§
ALEXANDRIA INSALACO, §
Defendant.
§
g
§g _
- - - JUDICIAL DISTRICT
TEMPORARY RESTRAINING ORDER
Plaintiff
Plaintiff D.
D. Alan Meeker ("Plaintiff'
(“Plaintiff’ or
or "Meeker"),
“Meeker”), has
has filed
filed aa verified
verified Application
Application for
for
Temporary Restraining
Restraining Order (the
(the "Application"),
“Application”), and in
in connection
connection with that
that Application
Application has
has
presented aa request
presented request for
for a
a Temporary Restraining
Restraining Order involving
involving Defendant Alexandria Insalaco
Insalaco
("Defendant"
(“Defendant” or
or "Insalaco").
“Insalaco”).
From the
the facts
facts set
set forth
forth in
in the
the Application,
Application, as
as verified
verified by
by Plaintiff,
Plaintiff, it
it clearly
clearly appears,
appears, and
the
the Court
Court finds,
finds, that
that unless
unless Defendant
Defendant is
is enjoined
enjoined from:
fiom: (i)
(i) contacting
contacting Meeker directly
directly or
or through
through
another
another person;
person; (ii)
(ii) causing
causing Meeker'
Meeker’ss telephone
telephone to
to ring,
ring, or
or any
any telephone
telephone possessed
possessed by
by his
his
children;
children; (iii)
(iii) sending
sending electronic
electronic communications
communications to
t0 Meeker,
Meeker, his
his children,
children, or
or any
any woman he
he is
is
dating,
dating, whether
whether directly
directly or
or through
through another
another person;
person; (iv)
(iv) being
being within
within 200 yards
yards of
0f Meeker or
or his
his
children;
children; (v)
(v) being
being within
Within 200 yards
yards ofMeeker's
of Meeker’s workplace at
at 100 Pier
Pier 1
1 Place
Place in
in Fort
Fort Worth,
Worth,
Texas;
Texas; (vi) being within
(vi) being within 200 yards
yards ofMeeker's
of Meeker’s children's
children’s respective
respective schools;
schools; (vii)
(vii) accessing
accessing any
any
computer,
computer, electronic
electronic device,
device, or
0r online
online profile
profile that
that Meeker or
or his
his children
children own or
0r maintain;
maintain; and
and
(viii)
(viii) discussing
discussing Meeker's business or
Meeker’s business personal affairs
or personal affairs with
with parties
parties adverse
adverse to
to Meeker or
or his
his
business
business interests
interests in
in any
any pending
pending or
or threatened
threatened litigation
litigation ("Adverse
(“Adverse Parties"),
Parties”), associates
associates of
of
Adverse Parties,
Parties, or
or attorneys
attorneys of
of Adverse Parties,
Parties, then
then it
it is
is probable
probable that
that Defendant
Defendant will
Will continue
continue
to
to improperly
impr0perly contact
contact or
or harass
harass Meeker in
in one or
or more of
0f these
these manners before
before longer
longer notice
notice can
can
be given
be given and before
before aa hearing
hearing is
is held
held on
0n an
an Application
Application for
for a
a Temporary Injunction.
Injunction. The Court
Court
2918003:.J
2918003J
further
further finds
finds that
that if
if the
the commission
commission of
0f these
these acts
acts is
is not
not immediately
immediately restrained
restrained and
and mandatorily
mandatorily
required,
required, as
as applicable,
applicable, Plaintiff
Plaintiff will
will suffer
suffer immediate
immediate and
and irreparable
irreparable injury
injury because,
because, at
at aa
minimum,
minimum, itit appears
appears that
that Defendant
Defendant is
is capable
capable and
and willing
willing to
t0 continue
continue to
t0 improperly
improperly contact,
contact,
communicate
communicate and/or
and/or harass
harass Meeker
Meeker in
in one
one or more of
0r more 0f these
these manners.
manners. Because
Because Plaintiffs
Plaintiffs has
has
established
established aa probable right of
probable right 0frecovery
recovery of
ofhis
his claims
claims including
including stalking,
stalking, conversion,
00nversion, violation
violation of
0f
the
the Texas
Texas Theft
Theft Liability
Liability Act,
Act, and
and negligence
negligence per
per se,
se, the
the harm
harm resulting
resulting by
by the
the acts
acts otherwise
otherwise
'
· restrained
restrained herein
herein would
would render
render any
any later
later money
moneyjudgment
judgment inadequate.
inadequate.
The
The relief
relief granted
granted herein
herein is
is effective
effective until
until the
the Court
Court hears,
hears, and
and rules
rules on, the Plaintiff's
on, the Plaintiff‘s
Application
Application for
for aa Temporary
Temporary Injunction,
Injunction, or
or until
until such
such time
time as
as this
this order
order expires
expires as
as aa matter
matter of
of
law.
law.
IT
IT IS THEREFORE ORDERED,
IS THEREFORE ORDERED, ADJUDGED AND DECREED
ADJUDGED AND DECREED that
that Defendant
Defendant and
and any
any
other
other persons
persons in
in active
active concert
concert or
or participation
participation with
with her Who receive
her who receive actual notice of
actual notice ofthis
this order
order by
by
personal
personal service
service or
or otherwise,
otherwise, from
from the date of
the date 0fentry
entry of
ofthis
this Order
Order until
until and
and through
through the
the 14th
14th day
day
after
after entry,
entry, or
or until further Order
until further Order of
ofthis
this Court,
Court, is
is restrained
restrained from:
from:
1.1. contacting
contacting Meeker
Meeker directly
directly or
or through
through another
another person;
person;
2.2. causing
causing Meeker'
Meeker’ss telephone
telephone to
t0 ring,
ring, or
0r any
any telephone
telephone possessed
possessed by
by his
his children;
children;
3.
3. sending
sending electronic
electronic communications
communications to to Meeker,
Meeker, his
his children,
children, or
or any woman he
any woman he is
is
dating,
dating, whether
whether directly
directly or
or through
through another
another person;
person;
4.
4. being
being within
within 200
200 yards
yards of
ofMeeker
Meeker or
0r his
his children;
children;
5.5. being
being within
within 200
200 yards
yards of
0f Meeker's
Meeker’s workplace
workplace at
at 100
100 Pier
Pier 11 Place
Place in
in Fort
Fort Worth,
Worth,
Texas;
Texas;
6.6. being
being within
within 200
200 yards
yards of
ofMeeker' s children's
Meeker’s children’s respective
respective schools;
schools;
7.7. accessing
accessing any
any computer,
computer, electronic
electronic device,
device, or
or online
online profile
profile that
that Meeker
Meeker or
or his
his
children own or
children own or maintain;
maintain; and
and
8.8. discussing
discussing Meeker'
Meeker’s s business
business or
0r personal
personal affairs
affairs with
with parties
parties adverse
adverse to
to Meeker
Meeker
or
0r his
his business
business interests
interests in
in any
any pending
pending oror threatened litigation ("Adverse
threatened litigation (“Adverse Parties"),
Parties”),
associates
associates ofofAdverse
Adverse Parties,
Parties, or
0r attorneys
attorneys of
ofAdverse
Adverse Parties.
Parties.
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IT IS FURTHER ORDERED ADJUDGED AND DECREED that Plaintiffs Application
for a Temporary Injunction be heard before this Court on the day 0f , 2019,
at o’clock a.m., in the Courtroom of the ___ Judicial District of Dallas County,
Texas, and that Defendant be cited to appear then and there to show cause, if any there be, why a
temporary injunction should not be issued as requested by Plaintiff. The Clerk of the Court is
hereby directed to issue a show cause notice t0 Defendant to appear at the temporary injunction
hearing.
The Clerk of the Court shall forthwith, on the filing by the Plaintiff of the bond
hereinafter required, and 0n approving the same according to law, issue this Temporary
Restraining Order and any necessary writ(s) in conformity with law and the terms 0f this Order.
This Order shall not be effective unless and until the Plaintiff executes and files with the
Clerk of the Court a bond, in conformity With the law, in the amount of $ . The
bond requirement may be satisfied by tender of a check from the firm 0f Kelly Hart and
Hallman LLP in the required amount.
SIGNED this day of , 2019, at o’clock, _.m.
The Honorable Judge of Said Court
2913003_1
Preview
DC-19-06300 CAUSE NO. _ _ _ __ D. ALAN MEEKER, §§ 0F IN THE DISTRICT COURT OF § Plaintiff, Plaintiff, §g § v. v. §g DALLAS COUNTY, TEXAS § ALEXANDRIA INSALACO, § Defendant. § g §g _ - - - JUDICIAL DISTRICT TEMPORARY RESTRAINING ORDER Plaintiff Plaintiff D. D. Alan Meeker ("Plaintiff' (“Plaintiff’ or or "Meeker"), “Meeker”), has has filed filed aa verified verified Application Application for for Temporary Restraining Restraining Order (the (the "Application"), “Application”), and in in connection connection with that that Application Application has has presented aa request presented request for for a a Temporary Restraining Restraining Order involving involving Defendant Alexandria Insalaco Insalaco ("Defendant" (“Defendant” or or "Insalaco"). “Insalaco”). From the the facts facts set set forth forth in in the the Application, Application, as as verified verified by by Plaintiff, Plaintiff, it it clearly clearly appears, appears, and the the Court Court finds, finds, that that unless unless Defendant Defendant is is enjoined enjoined from: fiom: (i) (i) contacting contacting Meeker directly directly or or through through another another person; person; (ii) (ii) causing causing Meeker' Meeker’ss telephone telephone to to ring, ring, or or any any telephone telephone possessed possessed by by his his children; children; (iii) (iii) sending sending electronic electronic communications communications to t0 Meeker, Meeker, his his children, children, or or any any woman he he is is dating, dating, whether whether directly directly or or through through another another person; person; (iv) (iv) being being within within 200 yards yards of 0f Meeker or or his his children; children; (v) (v) being being within Within 200 yards yards ofMeeker's of Meeker’s workplace at at 100 Pier Pier 1 1 Place Place in in Fort Fort Worth, Worth, Texas; Texas; (vi) being within (vi) being within 200 yards yards ofMeeker's of Meeker’s children's children’s respective respective schools; schools; (vii) (vii) accessing accessing any any computer, computer, electronic electronic device, device, or 0r online online profile profile that that Meeker or or his his children children own or 0r maintain; maintain; and and (viii) (viii) discussing discussing Meeker's business or Meeker’s business personal affairs or personal affairs with with parties parties adverse adverse to to Meeker or or his his business business interests interests in in any any pending pending or or threatened threatened litigation litigation ("Adverse (“Adverse Parties"), Parties”), associates associates of of Adverse Parties, Parties, or or attorneys attorneys of of Adverse Parties, Parties, then then it it is is probable probable that that Defendant Defendant will Will continue continue to to improperly impr0perly contact contact or or harass harass Meeker in in one or or more of 0f these these manners before before longer longer notice notice can can be given be given and before before aa hearing hearing is is held held on 0n an an Application Application for for a a Temporary Injunction. Injunction. The Court Court 2918003:.J 2918003J further further finds finds that that if if the the commission commission of 0f these these acts acts is is not not immediately immediately restrained restrained and and mandatorily mandatorily required, required, as as applicable, applicable, Plaintiff Plaintiff will will suffer suffer immediate immediate and and irreparable irreparable injury injury because, because, at at aa minimum, minimum, itit appears appears that that Defendant Defendant is is capable capable and and willing willing to t0 continue continue to t0 improperly improperly contact, contact, communicate communicate and/or and/or harass harass Meeker Meeker in in one one or more of 0r more 0f these these manners. manners. Because Because Plaintiffs Plaintiffs has has established established aa probable right of probable right 0frecovery recovery of ofhis his claims claims including including stalking, stalking, conversion, 00nversion, violation violation of 0f the the Texas Texas Theft Theft Liability Liability Act, Act, and and negligence negligence per per se, se, the the harm harm resulting resulting by by the the acts acts otherwise otherwise ' · restrained restrained herein herein would would render render any any later later money moneyjudgment judgment inadequate. inadequate. The The relief relief granted granted herein herein is is effective effective until until the the Court Court hears, hears, and and rules rules on, the Plaintiff's on, the Plaintiff‘s Application Application for for aa Temporary Temporary Injunction, Injunction, or or until until such such time time as as this this order order expires expires as as aa matter matter of of law. law. IT IT IS THEREFORE ORDERED, IS THEREFORE ORDERED, ADJUDGED AND DECREED ADJUDGED AND DECREED that that Defendant Defendant and and any any other other persons persons in in active active concert concert or or participation participation with with her Who receive her who receive actual notice of actual notice ofthis this order order by by personal personal service service or or otherwise, otherwise, from from the date of the date 0fentry entry of ofthis this Order Order until until and and through through the the 14th 14th day day after after entry, entry, or or until further Order until further Order of ofthis this Court, Court, is is restrained restrained from: from: 1.1. contacting contacting Meeker Meeker directly directly or or through through another another person; person; 2.2. causing causing Meeker' Meeker’ss telephone telephone to t0 ring, ring, or 0r any any telephone telephone possessed possessed by by his his children; children; 3. 3. sending sending electronic electronic communications communications to to Meeker, Meeker, his his children, children, or or any woman he any woman he is is dating, dating, whether whether directly directly or or through through another another person; person; 4. 4. being being within within 200 200 yards yards of ofMeeker Meeker or 0r his his children; children; 5.5. being being within within 200 200 yards yards of 0f Meeker's Meeker’s workplace workplace at at 100 100 Pier Pier 11 Place Place in in Fort Fort Worth, Worth, Texas; Texas; 6.6. being being within within 200 200 yards yards of ofMeeker' s children's Meeker’s children’s respective respective schools; schools; 7.7. accessing accessing any any computer, computer, electronic electronic device, device, or or online online profile profile that that Meeker Meeker or or his his children own or children own or maintain; maintain; and and 8.8. discussing discussing Meeker' Meeker’s s business business or 0r personal personal affairs affairs with with parties parties adverse adverse to to Meeker Meeker or 0r his his business business interests interests in in any any pending pending oror threatened litigation ("Adverse threatened litigation (“Adverse Parties"), Parties”), associates associates ofofAdverse Adverse Parties, Parties, or 0r attorneys attorneys of ofAdverse Adverse Parties. Parties. 2918003 I 2918003_1 IT IS FURTHER ORDERED ADJUDGED AND DECREED that Plaintiffs Application for a Temporary Injunction be heard before this Court on the day 0f , 2019, at o’clock a.m., in the Courtroom of the ___ Judicial District of Dallas County, Texas, and that Defendant be cited to appear then and there to show cause, if any there be, why a temporary injunction should not be issued as requested by Plaintiff. The Clerk of the Court is hereby directed to issue a show cause notice t0 Defendant to appear at the temporary injunction hearing. The Clerk of the Court shall forthwith, on the filing by the Plaintiff of the bond hereinafter required, and 0n approving the same according to law, issue this Temporary Restraining Order and any necessary writ(s) in conformity with law and the terms 0f this Order. This Order shall not be effective unless and until the Plaintiff executes and files with the Clerk of the Court a bond, in conformity With the law, in the amount of $ . The bond requirement may be satisfied by tender of a check from the firm 0f Kelly Hart and Hallman LLP in the required amount. SIGNED this day of , 2019, at o’clock, _.m. The Honorable Judge of Said Court 2913003_1