On February 17, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
Turcios, Cleofes Jose,
and
Trinh, Tony,
Trinh, Trinh,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
7/21/2023 2:00 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Treva Parker-Ayodele DEPUTY
CAUSE N0. DC-22-01952
CLEOFES JOSE TURCIOS IN THE DISTRICT COURT
Plaintiff,
vs. -
.
-
.
_
DALLAS COUNTY, TEXAS
TONY TRINH & TRINH TRINH '
,
192M) JUDICIAL Dr'srmcr
Defendant -
-
‘
PLAINTIFF’S MOTION FOR CONTINUANCE
NOW COMES Cleofes lose Turcios, Plaintiff in the above styled and numbered cause and
file this
'
-
Plainrifi’k Motion for'Continuance and respectfully shows the Court as follows:
I.
.
This case is scheduled for trial the week of August 7, 2023. This is the FIRST trial setting.
I
II.
Plaintiff is a multi-state truck driyer and will not return until late August or early September
of 2023'. 4
.
'III.
Counsel for Plaintiff have tried to confer with counsel for Defendants regarding the merits
of this motion by phone and email on Several occasions, but to date havenot received a
response.
Plaintiff’s Agreed Motion for Continuance '
Pagel
WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that the Court remove us from
the August 7th, 2023 trial docket. Counsel for Plaintiff would further request the Court to
A
reset this case at least 180 days from the current trial setting of August 7th, 2023
A
V.
ThisMotion is not tiled for purposes of delay but rather to ensure that justice may be done.
WHEREFORE, premises considered, we request that the case presently set for trial the week
8
I
of August 7*- be reset;
Respectfully submitted,
By //5/4
David S. Kohm
State Bar No. 11658563
Robin Singh
State Bar No. 24121981
DAVID S. KOHM & ASSOCIATES
1414 W. Randol Mill Road, Suite 118
Arlington, Texas 76012
Tel: (817) 226-8100 Fax: (817) 200-0111
Email: lit-efi1e@attorneykolun.com
ATTORNEYS FOR PLAINTIFF
'
Plaintiff’s Agreed Motion for Continuance
Page 2
CERTIFICATE op SERVICE
I certify that a true and correct copy of the foregoing instrument was served on the
following
counsel/parties of record in accordance with the Texas Rules of Civil Procedure on
2023, in the manner indicated:
By Electronic Service
LISA CHASTAIN & ASSOCLATES
-
TeschUssery
8675 Freeport Parkway
Irving, TX 75063
(817) 247-8009.
ATTORNEY FOR DEFENDANT TONYi& TRlNH TRINH
CERTIFICATE OF CONFERENCE
This is to certify that on the 11‘“, 14th and 20th day of July of 2023, our office attempted to
_
reach opposing counsel’s office regarding the merits of this Motion. via email and phone
with no response. Pursuant to that conversation, both Plaintiff s counsel and Defendant’s
counsel are in agreement with the filing of this motion.
Rohin Singh K", 6/ ‘
Plaintiff’s Agreed Motion for Continuance
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.
Envelope lD: 77766596
Filing Code Description: Non-Signed Proposed Order/Judgment
Filing Description: PROPOSED ORDER CONTINUANCE
Status as of 7/21/2023 3:23 PM CST
Associated Case Party: TONY TRINH
Name BarNumber Email TimestampSubmitted Status
Tesch Ussery DallasLegal@allstate.com 7/21/2023 2:00:49 PM SENT
Associated Case Party: CLEOFESJOSETURCIOS
Name BarNumber Email TimestampSubmitted Status
David Kohm 1 1658563 lit-efile@attorneykohm.com 7/21/2023 2:00:49 PM SENT
Document Filed Date
July 21, 2023
Case Filing Date
February 17, 2022
Category
MOTOR VEHICLE ACCIDENT
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FILED 7/21/2023 2:00 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Treva Parker-Ayodele DEPUTY CAUSE N0. DC-22-01952 CLEOFES JOSE TURCIOS IN THE DISTRICT COURT Plaintiff, vs. - . - . _ DALLAS COUNTY, TEXAS TONY TRINH & TRINH TRINH ' , 192M) JUDICIAL Dr'srmcr Defendant - - ‘ PLAINTIFF’S MOTION FOR CONTINUANCE NOW COMES Cleofes lose Turcios, Plaintiff in the above styled and numbered cause and file this ' - Plainrifi’k Motion for'Continuance and respectfully shows the Court as follows: I. . This case is scheduled for trial the week of August 7, 2023. This is the FIRST trial setting. I II. Plaintiff is a multi-state truck driyer and will not return until late August or early September of 2023'. 4 . 'III. Counsel for Plaintiff have tried to confer with counsel for Defendants regarding the merits of this motion by phone and email on Several occasions, but to date havenot received a response. Plaintiff’s Agreed Motion for Continuance ' Pagel WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that the Court remove us from the August 7th, 2023 trial docket. Counsel for Plaintiff would further request the Court to A reset this case at least 180 days from the current trial setting of August 7th, 2023 A V. ThisMotion is not tiled for purposes of delay but rather to ensure that justice may be done. WHEREFORE, premises considered, we request that the case presently set for trial the week 8 I of August 7*- be reset; Respectfully submitted, By //5/4 David S. Kohm State Bar No. 11658563 Robin Singh State Bar No. 24121981 DAVID S. KOHM & ASSOCIATES 1414 W. Randol Mill Road, Suite 118 Arlington, Texas 76012 Tel: (817) 226-8100 Fax: (817) 200-0111 Email: lit-efi1e@attorneykolun.com ATTORNEYS FOR PLAINTIFF ' Plaintiff’s Agreed Motion for Continuance Page 2 CERTIFICATE op SERVICE I certify that a true and correct copy of the foregoing instrument was served on the following counsel/parties of record in accordance with the Texas Rules of Civil Procedure on 2023, in the manner indicated: By Electronic Service LISA CHASTAIN & ASSOCLATES - TeschUssery 8675 Freeport Parkway Irving, TX 75063 (817) 247-8009. ATTORNEY FOR DEFENDANT TONYi& TRlNH TRINH CERTIFICATE OF CONFERENCE This is to certify that on the 11‘“, 14th and 20th day of July of 2023, our office attempted to _ reach opposing counsel’s office regarding the merits of this Motion. via email and phone with no response. Pursuant to that conversation, both Plaintiff s counsel and Defendant’s counsel are in agreement with the filing of this motion. Rohin Singh K", 6/ ‘ Plaintiff’s Agreed Motion for Continuance 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. Envelope lD: 77766596 Filing Code Description: Non-Signed Proposed Order/Judgment Filing Description: PROPOSED ORDER CONTINUANCE Status as of 7/21/2023 3:23 PM CST Associated Case Party: TONY TRINH Name BarNumber Email TimestampSubmitted Status Tesch Ussery DallasLegal@allstate.com 7/21/2023 2:00:49 PM SENT Associated Case Party: CLEOFESJOSETURCIOS Name BarNumber Email TimestampSubmitted Status David Kohm 1 1658563 lit-efile@attorneykohm.com 7/21/2023 2:00:49 PM SENT