On January 12, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Montoya, Gladi,
Montoya, Jose,
and
Torres, Fernando,
Torres Quality Homes, Llc,
for Contract - Consumer/Commercial/Debt (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Filed
1/16/2024 12:00 AM
Hidalgo County District Clerks
Reviewed By: Bella Pichardo
NO. 23-03614-3
STATE OF TEXAS IN THE COUNTY COURT
vs. AT LAW NO. 3
ALIYEH ANGEL LEMMER WILLIAMSON COUNTY, TEXAS
VERIFIED MOTION FOR CONTINUANCE
TO THE HONORABLE JUDGE OF SAID COURT:
Now comes Aliyeh Angel Lemmer, Defendant, by and through her attorney of record, Alex
R. Hernandez, Jr., and files this, Defendant’s Verified Motion for Continuance. In support thereof,
Defendant would show the following:
I
A pretrial hearing is scheduled in this cause on January 18, 2024 at 8:00 a.m. Trial is set for
January 24, 2024.
Il.
Defendant’s counsel is set for a jury trial in a civil matter on January 16, 2024, beginning at
8:30 a.m., in the Bexar County 57" Judicial District Court!. Additionally, after two Motions to
Compel and for Sanctions, Plaintiffs have still not been served discovery responses from either
Defendant and are filing a motion for death penalty sanctions along with the filing of this Motion for
Continuance. As such, Defendant requests a Continuance of the pretrial and trial setting until after
Counsel is out of trial in the Bexar matter and so that counsel may set his new Motion for death penalty
sanctions for hearing.
TIL.
This continuance is not sought for delay but so that justice may be done.
WHEREFORE, PREMISES CONSIDERED, Defendant PRAYS this honorable Court grant
this Motion for Continuance and all other reliefin law in equity to which Respondent may be entitled.
Respectfully submitted,
ds/ Alex R. Hernandez, Jr.
Alex R. Hernandez, Jr.
SBOT No. 24032411
ARH CONSULTING, LLC
402 W Main St.
Port Lavaca, TX 77979
Tel: (361) 792-3811
Fax: (361) 232-4975
alexhernandez@alexhernandeztriallaw.com
' This trial is set for three days and is expected to last the entire three days as the case is highly contested.
Electronically Filed
1/16/2024 12:00 AM
Hidalgo County District Clerks
Reviewed By: Bella Pichardo
CERTIFICATE OF SERVICE
I do hereby certify that a copy of the above and foregoing has been served upon all parties and/or
counsel of record.on this 15" day of January 2024.
/s/ Alex R. Hernandez, Jr.
* Alex R. Hernandez, Jr.
-
VERIFICATION
The undersigned states under oath: “I am the attorney for the movant in the foregoing Verified
Motion for Continuance. | have read the Motion. The statements contained in the Motion are within
my personal knowledge and are true and correct.”
Alex R. Hernandez, Jr.
SIGNED under oath before me on January 15, 2024,
ot Christina M Philen (la rwiloncs 9 -Philen
¥
My Commission Expires
Notary Public, State of Texas
a AF ID No 120409835
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.
Alex Hernandez J r.
Bar No. 24032411
alexhernandez@ alexhernandeztriallaw.com
Envelope ID: 83421166
Filing Code Description: Motion (No Fee)
Filing Description: PLAINTIFFS' MOTION FOR DISCOVERY
SANCTIONS RULE 215 TEXAS RULES CIVIL PROCEDURE
Status as of 1/16/2024 1:59 PM CST
Associated Case Party: J ose Montoya
Name BarNumber | Email TimestampS ubmitted Status
Alex R.Hernandez, J r. alexhernandez@ alexhernandeztriallaw.com | 1/15/2024 7:51:21 PM SENT
Alex Hernandez, J r. alexhernandez@ alexhernandeztriallaw.com | 1/15/2024 7:51:21 PM SENT
Adrian Baer a.baer@ alexhernandezcase.com 1/15/2024 7:51:21 PM ERROR
Alex Hernandez arh@ alexhernandezcase.com 1/15/2024 7:51:21 PM ERROR
Associated Case Party: Torres Quality Homes, LLC
Name BarNumber | Email TimestampS ubmitted Status
Marco De Luna marcodelunalaw@ gmail.com 1/15/2024 7:51:21 PM SENT
Marco De Luna del@ jdlawtx.com 1/15/2024 7:51:21 PM SENT
Marco DeLuna marcodelunalaw@ gmail.com 1/15/2024 7:51:21 PM SENT
Case Contacts
Name BarNumber | Email TimestampS ubmitted Status
JESSICA DE LUNA DELUNALAWGROUP@GMAIL.COM 1/15/2024 7:51:21 PM SENT
Karalynn C.Cromeens karalynn@ thecromeenslawfirm.com 1/15/2024 7:51:21 PM SENT
J oseph Munoz jmunoz@ thecromeenslawfirm.com 1/15/2024 7:51:21 PM SENT
J uan-Carlos Carbajal juancarbajal@ alexhernandezcase.com 1/15/2024 7:51:21 PM ERROR
DIANA PEREZ D.PEREZ@ALEXHERNANDEZCASE.COM 1/15/2024 7:51:21 PM ERROR
J essica Carbajal J .Carbajal@ alexhernandezcase.com 1/15/2024 7:51:21 PM ERROR
Document Filed Date
January 16, 2024
Case Filing Date
January 12, 2021
Category
Contract - Consumer/Commercial/Debt (OCA)
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Electronically Filed 1/16/2024 12:00 AM Hidalgo County District Clerks Reviewed By: Bella Pichardo NO. 23-03614-3 STATE OF TEXAS IN THE COUNTY COURT vs. AT LAW NO. 3 ALIYEH ANGEL LEMMER WILLIAMSON COUNTY, TEXAS VERIFIED MOTION FOR CONTINUANCE TO THE HONORABLE JUDGE OF SAID COURT: Now comes Aliyeh Angel Lemmer, Defendant, by and through her attorney of record, Alex R. Hernandez, Jr., and files this, Defendant’s Verified Motion for Continuance. In support thereof, Defendant would show the following: I A pretrial hearing is scheduled in this cause on January 18, 2024 at 8:00 a.m. Trial is set for January 24, 2024. Il. Defendant’s counsel is set for a jury trial in a civil matter on January 16, 2024, beginning at 8:30 a.m., in the Bexar County 57" Judicial District Court!. Additionally, after two Motions to Compel and for Sanctions, Plaintiffs have still not been served discovery responses from either Defendant and are filing a motion for death penalty sanctions along with the filing of this Motion for Continuance. As such, Defendant requests a Continuance of the pretrial and trial setting until after Counsel is out of trial in the Bexar matter and so that counsel may set his new Motion for death penalty sanctions for hearing. TIL. This continuance is not sought for delay but so that justice may be done. WHEREFORE, PREMISES CONSIDERED, Defendant PRAYS this honorable Court grant this Motion for Continuance and all other reliefin law in equity to which Respondent may be entitled. Respectfully submitted, ds/ Alex R. Hernandez, Jr. Alex R. Hernandez, Jr. SBOT No. 24032411 ARH CONSULTING, LLC 402 W Main St. Port Lavaca, TX 77979 Tel: (361) 792-3811 Fax: (361) 232-4975 alexhernandez@alexhernandeztriallaw.com ' This trial is set for three days and is expected to last the entire three days as the case is highly contested. Electronically Filed 1/16/2024 12:00 AM Hidalgo County District Clerks Reviewed By: Bella Pichardo CERTIFICATE OF SERVICE I do hereby certify that a copy of the above and foregoing has been served upon all parties and/or counsel of record.on this 15" day of January 2024. /s/ Alex R. Hernandez, Jr. * Alex R. Hernandez, Jr. - VERIFICATION The undersigned states under oath: “I am the attorney for the movant in the foregoing Verified Motion for Continuance. | have read the Motion. The statements contained in the Motion are within my personal knowledge and are true and correct.” Alex R. Hernandez, Jr. SIGNED under oath before me on January 15, 2024, ot Christina M Philen (la rwiloncs 9 -Philen ¥ My Commission Expires Notary Public, State of Texas a AF ID No 120409835 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. Alex Hernandez J r. Bar No. 24032411 alexhernandez@ alexhernandeztriallaw.com Envelope ID: 83421166 Filing Code Description: Motion (No Fee) Filing Description: PLAINTIFFS' MOTION FOR DISCOVERY SANCTIONS RULE 215 TEXAS RULES CIVIL PROCEDURE Status as of 1/16/2024 1:59 PM CST Associated Case Party: J ose Montoya Name BarNumber | Email TimestampS ubmitted Status Alex R.Hernandez, J r. alexhernandez@ alexhernandeztriallaw.com | 1/15/2024 7:51:21 PM SENT Alex Hernandez, J r. alexhernandez@ alexhernandeztriallaw.com | 1/15/2024 7:51:21 PM SENT Adrian Baer a.baer@ alexhernandezcase.com 1/15/2024 7:51:21 PM ERROR Alex Hernandez arh@ alexhernandezcase.com 1/15/2024 7:51:21 PM ERROR Associated Case Party: Torres Quality Homes, LLC Name BarNumber | Email TimestampS ubmitted Status Marco De Luna marcodelunalaw@ gmail.com 1/15/2024 7:51:21 PM SENT Marco De Luna del@ jdlawtx.com 1/15/2024 7:51:21 PM SENT Marco DeLuna marcodelunalaw@ gmail.com 1/15/2024 7:51:21 PM SENT Case Contacts Name BarNumber | Email TimestampS ubmitted Status JESSICA DE LUNA DELUNALAWGROUP@GMAIL.COM 1/15/2024 7:51:21 PM SENT Karalynn C.Cromeens karalynn@ thecromeenslawfirm.com 1/15/2024 7:51:21 PM SENT J oseph Munoz jmunoz@ thecromeenslawfirm.com 1/15/2024 7:51:21 PM SENT J uan-Carlos Carbajal juancarbajal@ alexhernandezcase.com 1/15/2024 7:51:21 PM ERROR DIANA PEREZ D.PEREZ@ALEXHERNANDEZCASE.COM 1/15/2024 7:51:21 PM ERROR J essica Carbajal J .Carbajal@ alexhernandezcase.com 1/15/2024 7:51:21 PM ERROR