On April 20, 2022 a
MOTION FOR CONTINUANCE - MOTION - CONTINUANCE
was filed
involving a dispute between
City Of Dallas,
and
5050 Cleveland Road, Dallas Texas, In Rem,
Lyons, Germaud L.,
St. John Missionary Baptist Church Inc. Of Dallas Texas,
for CODE VIOLATIONS
in the District Court of Dallas County.
Preview
FILED
11/29/2023 8:58 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Lauren Beavers DEPUTY
CAUSE NO. DC-22-04104
CITY OF DALLAS, TEXAS IN THE DISTRICT COURT
§§§§§§§§§§§§§§§§
Plaintiffs,
VS.
192ml JUDICIAL DISTRICT
ST JOHN MISSIONARY
BAPTIST CHURCH, INC. 0F DALLAS
TEXAS; GERMAUD L/ LYONS
a/k/a BOSSMAN BUBBA;
and 5050 CLEVELAND ROAD,
DALLAS, TEXAS, in rem
Defendants, DALLAS COUNTY, TEXAS
MOTION FOR CONTINUAN CE OF TRIAL DATE
TO THE HONORABLE JUDGE OF THE COURT:
Plaintiff, City of Dallas (“the City”), files this Motion for Continuance of Trial Date and
would respectfully Show the Court the following:
l. The City filed its original petition on April 20, 2022, pursuant to Chapter 54 of
the Texas Local Government Code to address outstanding Violations of the Dallas City
Code.
2. This case is currently set for trial on December ll, 2023.
3. The parties have attended mediation and are working towards a final settlement
of the case.
4. A continuance is also sought because the Plaintiff and Defendant have motions
pending before the Court and the parties need more time to have those motions set and
heard. Specifically, the City has a motion to hold Defendant in contempt, two motions
Motion for Continuance of Trial Date
to quash, and is entitled to discovery. Defendant has a plea to the jurisdiction pending, a
motion to disqualify the City’s lead counsel, a motion to compel the deposition of Jill
Haning and Robert Beltran, and a motion to reconsider.
5. The City requests that the trial date be rescheduled from its current setting on
December ll, 2023, to a setting no earlier than June ll, 2024.
6. The City requests that the trial be re-set not for delay, but so that justice may be
done.
WHEREFORE, PREMISES CONSIDERED, the City requests that this Court re-set
the trial date from December 11, 2023, to an available date no earlier than six (6) months from
the currently scheduled trial date, and for such other and further relief, general or special, in law
or in equity, to which Plaintiff may be entitled.
Respectfully submitted,
CITY ATTORNEY OF THE CITY OF DALLAS
Tammy Palomino
City Attorney
/s/ Kelle Bisho
LAUREN “KELLEY” BISHOP
Assistant City Attorney
State Bar No. 24096865
lauren.bishop@dallascityhall.com
City Attomey’s Office
1500 Marilla Street, 7DN
Dallas, Texas 75201
Telephone: 214-670-3519
Facsimile: 214-670-0622
ATTORNEYS FOR THE CITY OF DALLAS
Motion for Continuance of Trial Date
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document was served upon
Defendants, through their Attorney of record Jonathan Chatmon, Via E—service at
1chatmon.chatmon@gmail.corn pursuant to the Texas Rules of Civil Procedure on November
29, 2023.
Kelle Bisho
/s/
Kelley Bishop
ATTORNEY FOR PLAINTIFF
CERTIFICATE OF CONFERENCE
On November 28, 2023, a copy of the foregoing motion was provided to counsel for
Defendant, and Defendant’s counsel is unopposed to the relief requested.
Certified to the Day 28th of November 2023 by:
Kelle Bisho
/s/
Kelley Bishop
Motion for Continuance of Trial Date
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.
Marc Quarles on behalf of Andrew Gilbert
Bar No. 24012696
marc.quarles@dallas.gov
Envelope ID: 82037059
Filing Code Description: Motion - Continuance
Filing Description:
Status as of 11/29/2023 10:57 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Andrew Gilbert andrewgilbert@dallascityhall.com 11/29/2023 8:58:10 AM SENT
Marc Quarles marc.quarles@dallascityhalLoom 11/29/2023 8:58:10 AM SENT
Jill Haning jill.haning@dallascityhall.com 11/29/2023 8:58:10 AM SENT
Julius Jenkins 24104692 julius.jenkins@dallas.gov 11/29/2023 8:58:10 AM SENT
Lauren KelleyBishop lauren.bishop@dallascityhall.com 11/29/2023 8:58:10 AM SENT
John Shipp JOHN@SH|PPADR.COM 11/29/2023 8:58:10 AM SENT
Associated Case Party: CITY OF DALLAS
Name BarNumber Email TimestampSubmitted Status
Angie G.Morgan angelica.morgan@dallascityhall.com 11/29/2023 8:58:10 AM SENT
James Farrior james.farrior@dallas.gov 11/29/2023 8:58:10 AM SENT
Associated Case Party: ST. JOHN MISSIONARY BAPTIST CHURCH INC. OF
DALLAS TEXAS
Name BarNumber Email TimestampSubmitted Status
Jonathan Chatmon Ichatmon.chatmon@gmail.com 11/29/2023 8:58:10 AM SENT
Emmanuelle Payas emmanuelIe@lchatmonassociates.com 11/29/2023 8:58:10 AM SENT
Michelle Anne Francisco michelle@lchatmonassociatescom 11/29/2023 8:58:10 AM ERROR
Bea de Leon bae@lchatmonassociates.com 11/29/2023 8:58:10 AM SENT
Jeraldine Pinar jeraldine@lchatmonassociates.com 11/29/2023 8:58:10 AM SENT
Associated Case Party: GERMAUDL.LYONS
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.
Marc Quarles on behalf of Andrew Gilbert
Bar No. 24012696
marc.quarles@dallas.gov
Envelope ID: 82037059
Filing Code Description: Motion - Continuance
Filing Description:
Status as of 11/29/2023 10:57 AM CST
Associated Case Party: GERMAUDL.LYONS
Name BarNumber Email TimestampSubmitted Status
Germaud Lyons etransllc1@gmail.com 11/29/2023 8:58:10 AM SENT
Document Filed Date
November 29, 2023
Case Filing Date
April 20, 2022
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FILED 11/29/2023 8:58 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Lauren Beavers DEPUTY CAUSE NO. DC-22-04104 CITY OF DALLAS, TEXAS IN THE DISTRICT COURT §§§§§§§§§§§§§§§§ Plaintiffs, VS. 192ml JUDICIAL DISTRICT ST JOHN MISSIONARY BAPTIST CHURCH, INC. 0F DALLAS TEXAS; GERMAUD L/ LYONS a/k/a BOSSMAN BUBBA; and 5050 CLEVELAND ROAD, DALLAS, TEXAS, in rem Defendants, DALLAS COUNTY, TEXAS MOTION FOR CONTINUAN CE OF TRIAL DATE TO THE HONORABLE JUDGE OF THE COURT: Plaintiff, City of Dallas (“the City”), files this Motion for Continuance of Trial Date and would respectfully Show the Court the following: l. The City filed its original petition on April 20, 2022, pursuant to Chapter 54 of the Texas Local Government Code to address outstanding Violations of the Dallas City Code. 2. This case is currently set for trial on December ll, 2023. 3. The parties have attended mediation and are working towards a final settlement of the case. 4. A continuance is also sought because the Plaintiff and Defendant have motions pending before the Court and the parties need more time to have those motions set and heard. Specifically, the City has a motion to hold Defendant in contempt, two motions Motion for Continuance of Trial Date to quash, and is entitled to discovery. Defendant has a plea to the jurisdiction pending, a motion to disqualify the City’s lead counsel, a motion to compel the deposition of Jill Haning and Robert Beltran, and a motion to reconsider. 5. The City requests that the trial date be rescheduled from its current setting on December ll, 2023, to a setting no earlier than June ll, 2024. 6. The City requests that the trial be re-set not for delay, but so that justice may be done. WHEREFORE, PREMISES CONSIDERED, the City requests that this Court re-set the trial date from December 11, 2023, to an available date no earlier than six (6) months from the currently scheduled trial date, and for such other and further relief, general or special, in law or in equity, to which Plaintiff may be entitled. Respectfully submitted, CITY ATTORNEY OF THE CITY OF DALLAS Tammy Palomino City Attorney /s/ Kelle Bisho LAUREN “KELLEY” BISHOP Assistant City Attorney State Bar No. 24096865 lauren.bishop@dallascityhall.com City Attomey’s Office 1500 Marilla Street, 7DN Dallas, Texas 75201 Telephone: 214-670-3519 Facsimile: 214-670-0622 ATTORNEYS FOR THE CITY OF DALLAS Motion for Continuance of Trial Date CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served upon Defendants, through their Attorney of record Jonathan Chatmon, Via E—service at 1chatmon.chatmon@gmail.corn pursuant to the Texas Rules of Civil Procedure on November 29, 2023. Kelle Bisho /s/ Kelley Bishop ATTORNEY FOR PLAINTIFF CERTIFICATE OF CONFERENCE On November 28, 2023, a copy of the foregoing motion was provided to counsel for Defendant, and Defendant’s counsel is unopposed to the relief requested. Certified to the Day 28th of November 2023 by: Kelle Bisho /s/ Kelley Bishop Motion for Continuance of Trial Date 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. Marc Quarles on behalf of Andrew Gilbert Bar No. 24012696 marc.quarles@dallas.gov Envelope ID: 82037059 Filing Code Description: Motion - Continuance Filing Description: Status as of 11/29/2023 10:57 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Andrew Gilbert andrewgilbert@dallascityhall.com 11/29/2023 8:58:10 AM SENT Marc Quarles marc.quarles@dallascityhalLoom 11/29/2023 8:58:10 AM SENT Jill Haning jill.haning@dallascityhall.com 11/29/2023 8:58:10 AM SENT Julius Jenkins 24104692 julius.jenkins@dallas.gov 11/29/2023 8:58:10 AM SENT Lauren KelleyBishop lauren.bishop@dallascityhall.com 11/29/2023 8:58:10 AM SENT John Shipp JOHN@SH|PPADR.COM 11/29/2023 8:58:10 AM SENT Associated Case Party: CITY OF DALLAS Name BarNumber Email TimestampSubmitted Status Angie G.Morgan angelica.morgan@dallascityhall.com 11/29/2023 8:58:10 AM SENT James Farrior james.farrior@dallas.gov 11/29/2023 8:58:10 AM SENT Associated Case Party: ST. JOHN MISSIONARY BAPTIST CHURCH INC. OF DALLAS TEXAS Name BarNumber Email TimestampSubmitted Status Jonathan Chatmon Ichatmon.chatmon@gmail.com 11/29/2023 8:58:10 AM SENT Emmanuelle Payas emmanuelIe@lchatmonassociates.com 11/29/2023 8:58:10 AM SENT Michelle Anne Francisco michelle@lchatmonassociatescom 11/29/2023 8:58:10 AM ERROR Bea de Leon bae@lchatmonassociates.com 11/29/2023 8:58:10 AM SENT Jeraldine Pinar jeraldine@lchatmonassociates.com 11/29/2023 8:58:10 AM SENT Associated Case Party: GERMAUDL.LYONS 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. Marc Quarles on behalf of Andrew Gilbert Bar No. 24012696 marc.quarles@dallas.gov Envelope ID: 82037059 Filing Code Description: Motion - Continuance Filing Description: Status as of 11/29/2023 10:57 AM CST Associated Case Party: GERMAUDL.LYONS Name BarNumber Email TimestampSubmitted Status Germaud Lyons etransllc1@gmail.com 11/29/2023 8:58:10 AM SENT