On November 01, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Brown, Keyandre J.,
Watkins, Miekisha C.,
and
Flores-Hampton, Lourdes,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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FILED
11/8/2022 12:06 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Cassandra Walker DEPUTY
CAUSE NO. DC-19-17613
MIEKISHA C. WATKINS AND § IN THE DISTRICT COURT
KEYANDRE J. BROWN §
Plainttffs, §
§
v. §
§ IOIST JUDICIAL DISTRICT
§
§
LOURDES FLORES-HAMPTON §
Defendant. § DALLAS COUNTY, TEXAS
MOTION TO LIFT AUTOMATIC STAY
COMES NOW Defendant Lourdes Flores-Hampton and files this Motion to Lift the
Automatic Stay and reinstate this lawsuit to the Court’s active docket, as follows:
1. Defendant’s insurance carrier, ACCC Insurance Company (“ACCC”), was
declared insolvent by the Texas Commissioner of Insurance on December 30, 2020. As such, this
lawsuit is subject to the Texas Property and Casualty Insurance Guaranty Act (TPCIGA), TEX.
INS. CODE § 462.001 et seq. Pursuant to TEX. INS. CODE § 462.309, this matter was automatically
stayed from action for a period of six months to expire on June 30, 2021. Notice of the automatic
stay was filed with the Court on December 22, 2020.
2. The statutory stay period has now expired, and the parties wish for this matter to be
reinstated to the Court’s active docket.
WHEREFORE, the Defendant prays the Court grant this Motion to Lift Automatic Stay,
reinstate this case to the Court’s active docket, and set this matter for trial.
Motion to LiftAutomatic Stay (145.0056) Page 1 of 2
Respectfully submitted,
THE WILLIS LAW GROUP
/s/ Shelbie Bradley
ADAM C. GALLEGOS
State Bar No. 24036614
SHELBIE BRADLEY
State Bar N0. 24096205
KIRK D. WILLIS
State Bar N0. 21648500
1985 Forest Lane
Garland, Texas 75240
Telephone: 214-736-9433
Facsimile: 214-736-9994
E-Service only: service@thewillislawgroupeom
ATTORNEYS FOR DEFENDANT
LOURDES FLORES-HAMPTON
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing document
has been forwarded to all counsel of record Via E-Service on the 8th day of November, 2022.
Via E-Service: eservice@benabbott.com
Griffin Scheumack
SBN 24097168
Ben Abbott and Associates, PLLC
1934 Pendleton Dr.
Garland, Texas 75041
Phone: 972-263-5555
Fax: 972-682-7586
ATTORNEY FOR PLAINTIFFS
s/ Shelbie Bradlev
SHELBIE BRADLEY
CERTIFICATE OF CONFERENCE
The undersigned attorney attempted to contact counsel for Plaintiff Miekisha C. Watkins
and Keyandre J. Brown on multiple occasions Via telephone and Via e-mail to discuss the foregoing
motion. Counsel for respondent has failed to respond.
s/ Shelbie Brgdlev
SHELBIE BRADLEY
Motion to Lift Automatic Stay (145. 0056) Page 2 of 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.
Samuel Holmes on behalf of Shelbie Bradley
Bar No. 24096205
sholmes@thewillislawgroup.com
Envelope ID: 69977805
Status as of 11/9/2022 9:37 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
William W. Alexander balexander@zalaw.net 11/8/2022 12:06:55 PM SENT
Griffin Scheumack 24097168 legal@mytexasfirm.com 11/8/2022 12:06:55 PM SENT
Associated Case Party: LOURDES FLORES-HAMPTON
Name BarNumber Email TimestampSubmitted Status
Adam C.Gallegos service@thewillislawgroup.com 11/8/2022 12:06:55 PM SENT
Nora Casillas ncasillas@zalaw.net 11/8/2022 12:06:55 PM SENT
Document Filed Date
November 08, 2022
Case Filing Date
November 01, 2019
Category
MOTOR VEHICLE ACCIDENT
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FILED 11/8/2022 12:06 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Cassandra Walker DEPUTY CAUSE NO. DC-19-17613 MIEKISHA C. WATKINS AND § IN THE DISTRICT COURT KEYANDRE J. BROWN § Plainttffs, § § v. § § IOIST JUDICIAL DISTRICT § § LOURDES FLORES-HAMPTON § Defendant. § DALLAS COUNTY, TEXAS MOTION TO LIFT AUTOMATIC STAY COMES NOW Defendant Lourdes Flores-Hampton and files this Motion to Lift the Automatic Stay and reinstate this lawsuit to the Court’s active docket, as follows: 1. Defendant’s insurance carrier, ACCC Insurance Company (“ACCC”), was declared insolvent by the Texas Commissioner of Insurance on December 30, 2020. As such, this lawsuit is subject to the Texas Property and Casualty Insurance Guaranty Act (TPCIGA), TEX. INS. CODE § 462.001 et seq. Pursuant to TEX. INS. CODE § 462.309, this matter was automatically stayed from action for a period of six months to expire on June 30, 2021. Notice of the automatic stay was filed with the Court on December 22, 2020. 2. The statutory stay period has now expired, and the parties wish for this matter to be reinstated to the Court’s active docket. WHEREFORE, the Defendant prays the Court grant this Motion to Lift Automatic Stay, reinstate this case to the Court’s active docket, and set this matter for trial. Motion to LiftAutomatic Stay (145.0056) Page 1 of 2 Respectfully submitted, THE WILLIS LAW GROUP /s/ Shelbie Bradley ADAM C. GALLEGOS State Bar No. 24036614 SHELBIE BRADLEY State Bar N0. 24096205 KIRK D. WILLIS State Bar N0. 21648500 1985 Forest Lane Garland, Texas 75240 Telephone: 214-736-9433 Facsimile: 214-736-9994 E-Service only: service@thewillislawgroupeom ATTORNEYS FOR DEFENDANT LOURDES FLORES-HAMPTON CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing document has been forwarded to all counsel of record Via E-Service on the 8th day of November, 2022. Via E-Service: eservice@benabbott.com Griffin Scheumack SBN 24097168 Ben Abbott and Associates, PLLC 1934 Pendleton Dr. Garland, Texas 75041 Phone: 972-263-5555 Fax: 972-682-7586 ATTORNEY FOR PLAINTIFFS s/ Shelbie Bradlev SHELBIE BRADLEY CERTIFICATE OF CONFERENCE The undersigned attorney attempted to contact counsel for Plaintiff Miekisha C. Watkins and Keyandre J. Brown on multiple occasions Via telephone and Via e-mail to discuss the foregoing motion. Counsel for respondent has failed to respond. s/ Shelbie Brgdlev SHELBIE BRADLEY Motion to Lift Automatic Stay (145. 0056) Page 2 of 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. Samuel Holmes on behalf of Shelbie Bradley Bar No. 24096205 sholmes@thewillislawgroup.com Envelope ID: 69977805 Status as of 11/9/2022 9:37 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status William W. Alexander balexander@zalaw.net 11/8/2022 12:06:55 PM SENT Griffin Scheumack 24097168 legal@mytexasfirm.com 11/8/2022 12:06:55 PM SENT Associated Case Party: LOURDES FLORES-HAMPTON Name BarNumber Email TimestampSubmitted Status Adam C.Gallegos service@thewillislawgroup.com 11/8/2022 12:06:55 PM SENT Nora Casillas ncasillas@zalaw.net 11/8/2022 12:06:55 PM SENT