On April 26, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Red Target Llc Dba Scj Commercial Financial Services,
and
Lobos Rm Trucking Llc,
Rendon, Manuel,
Rendon, Maria,
Rendon, Rocio,
for Contract - Other Contract (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Submitted
2/13/2024 12:00 PM
Hidalgo County Clerk
Accepted by: Sarah Reyes
CAUSE NO. CL-23-1729-I
RED TARGET LLC DBA SCJ § IN THE COUNTY COURT
COMMERCIAL FINANCIAL § Hidalgo County, Texas
SERVICES,
PLAINTIFF
v. § Hidalgo County Court at Law #9
§
Lobos RM Trucking LLC, § 100 N. Closner Blvd.
Manuel Rendon, Rocio Rendon, Maria Edinburg, TX 78539
Rendon
DEFENDANT §
§
AMENDED MOTION FOR CONTINUANCE
Comes now, Manuel Rendon, Rocio Rendon, and Maria Rendon through their Attorney,
Hooman Khoshnood file this Amended Motion for Continuance.
1. This case is presently set for a hearing on Plaintiff’s Motion for Summary Judgment on
02/14/2024 at 09:30 AM.
2. While attempting to arrive at a potential resolution to the case on 2/11/2024, the Defendants’
attorney was disclosed information that makes it virtually impossible to represent the best
interest of all the defendants simultaneously in the case.
3. Currently, it would be an obvious conflict of interest for the Defendants’ attorney to continue
representing the Defendants.
4. Therefore, the Defendants’ attorney requests a continuance so that he can inform the
Defendants of their statutory disclosures via snail mail, give the Defendants time to obtain new
counsel and enable the Defendants’ attorney to file a Motion to Withdraw as Counsel.
5. This amended Motion for Continuance is being filed the day before the hearing, because the
information that creates the conflict of interest was discovered yesterday (2/12/2024).
6. Should the Court require a hearing tomorrow; the Defendants’ attorney respectfully asks for a
telephonic or virtual hearing to present the very little he can ethically discuss regarding his
intention to withdraw as counsel.
Electronically Submitted
2/13/2024 12:00 PM
Hidalgo County Clerk
Accepted by: Sarah Reyes
Wherefore the Defendants’ counsel request (1) a continuance long enough for the defendants to
make an informed decision and to obtain new counsel if they so desire; (2) Allow the
Defendants’ counsel to fulfil its obligations relating to his withdrawal; (3) Enable the
Defendants’ counsel to file a Motion to withdraw; (4) to grant a virtual or telephonic hearing if
one is necessary tomorrow; and (5) grant any other relief the Court deems just.
Respectfully submitted,
Signature of Attorney,
Printed Name: Hooman Khoshnood
Hooman Khoshnood Law PC
Address: 8701 TX-71, Suite 201Q
Austin, TX 78735
Telephone: (512) 866-9811
State Bar No.: 24122796
Signature of Attorney,
Printed Name: Hooman Khoshnood
Hooman Khoshnood Law PC
Address: 8701 TX-71, Suite 201Q
Austin, TX 78735
Telephone: (512) 866-9811
State Bar No.: 24122796
☒ Defendant consents to email service of all motions, pleadings, and other documents filed in
this proceeding to be delivered to the following e-mail address: hooman@hklawpc.com
CERTIFICATE OF SERVICE
I hereby certify that a copy of this Answer was served on the Plaintiff on 2/13/24 pursuant to Texas
Rule of Civil Procedure 501.4 by:
☐ Personal delivery
Electronically Submitted
2/13/2024 12:00 PM
Hidalgo County Clerk
Accepted by: Sarah Reyes
☐ Mail
☐ Fax
☒ Email : Ian@barnettgarcia.com
☒ Another method approved by the court: E-Service
Attorney for Defendants’ Signature
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.
Hooman Khoshnood on behalf of Hooman Khoshnood
Bar No. 24122796
hooman@hklawpc.com
Envelope ID: 84450909
Filing Code Description: Amended Filing
Filing Description: Amended Motion for Continuance
Status as of 2/13/2024 12:02 PM CST
Associated Case Party: RED TARGET LLC DBA SCJ COMMERCIAL FINANCIAL
SERVICES
Name BarNumber Email TimestampSubmitted Status
Ian McCarthy ian@barnettgarcia.com 2/13/2024 12:00:50 PM SENT
Associated Case Party: LOBOS RM TRUCKING LLC
Name BarNumber Email TimestampSubmitted Status
Hooman Khoshnood 24122796 hooman@hklawpc.com 2/13/2024 12:00:50 PM SENT
Associated Case Party: MANUEL RENDON
Name BarNumber Email TimestampSubmitted Status
Hooman Khoshnood hooman@hklawpc.com 2/13/2024 12:00:50 PM SENT
Associated Case Party: ROCIO RENDON
Name BarNumber Email TimestampSubmitted Status
Hooman Khoshnood hooman@hklawpc.com 2/13/2024 12:00:50 PM SENT
Associated Case Party: MARIA RENDON
Name BarNumber Email TimestampSubmitted Status
Hooman Khoshnood hooman@hklawpc.com 2/13/2024 12:00:50 PM SENT
Case Contacts
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.
Hooman Khoshnood on behalf of Hooman Khoshnood
Bar No. 24122796
hooman@hklawpc.com
Envelope ID: 84450909
Filing Code Description: Amended Filing
Filing Description: Amended Motion for Continuance
Status as of 2/13/2024 12:02 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
assuredcivilprocessagency @yahoo.com assuredcivilprocessagency@yahoo.com 2/13/2024 12:00:50 PM SENT
Document Filed Date
February 13, 2024
Case Filing Date
April 26, 2023
Category
Contract - Other Contract (OCA)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Electronically Submitted 2/13/2024 12:00 PM Hidalgo County Clerk Accepted by: Sarah Reyes CAUSE NO. CL-23-1729-I RED TARGET LLC DBA SCJ § IN THE COUNTY COURT COMMERCIAL FINANCIAL § Hidalgo County, Texas SERVICES, PLAINTIFF v. § Hidalgo County Court at Law #9 § Lobos RM Trucking LLC, § 100 N. Closner Blvd. Manuel Rendon, Rocio Rendon, Maria Edinburg, TX 78539 Rendon DEFENDANT § § AMENDED MOTION FOR CONTINUANCE Comes now, Manuel Rendon, Rocio Rendon, and Maria Rendon through their Attorney, Hooman Khoshnood file this Amended Motion for Continuance. 1. This case is presently set for a hearing on Plaintiff’s Motion for Summary Judgment on 02/14/2024 at 09:30 AM. 2. While attempting to arrive at a potential resolution to the case on 2/11/2024, the Defendants’ attorney was disclosed information that makes it virtually impossible to represent the best interest of all the defendants simultaneously in the case. 3. Currently, it would be an obvious conflict of interest for the Defendants’ attorney to continue representing the Defendants. 4. Therefore, the Defendants’ attorney requests a continuance so that he can inform the Defendants of their statutory disclosures via snail mail, give the Defendants time to obtain new counsel and enable the Defendants’ attorney to file a Motion to Withdraw as Counsel. 5. This amended Motion for Continuance is being filed the day before the hearing, because the information that creates the conflict of interest was discovered yesterday (2/12/2024). 6. Should the Court require a hearing tomorrow; the Defendants’ attorney respectfully asks for a telephonic or virtual hearing to present the very little he can ethically discuss regarding his intention to withdraw as counsel. Electronically Submitted 2/13/2024 12:00 PM Hidalgo County Clerk Accepted by: Sarah Reyes Wherefore the Defendants’ counsel request (1) a continuance long enough for the defendants to make an informed decision and to obtain new counsel if they so desire; (2) Allow the Defendants’ counsel to fulfil its obligations relating to his withdrawal; (3) Enable the Defendants’ counsel to file a Motion to withdraw; (4) to grant a virtual or telephonic hearing if one is necessary tomorrow; and (5) grant any other relief the Court deems just. Respectfully submitted, Signature of Attorney, Printed Name: Hooman Khoshnood Hooman Khoshnood Law PC Address: 8701 TX-71, Suite 201Q Austin, TX 78735 Telephone: (512) 866-9811 State Bar No.: 24122796 Signature of Attorney, Printed Name: Hooman Khoshnood Hooman Khoshnood Law PC Address: 8701 TX-71, Suite 201Q Austin, TX 78735 Telephone: (512) 866-9811 State Bar No.: 24122796 ☒ Defendant consents to email service of all motions, pleadings, and other documents filed in this proceeding to be delivered to the following e-mail address: hooman@hklawpc.com CERTIFICATE OF SERVICE I hereby certify that a copy of this Answer was served on the Plaintiff on 2/13/24 pursuant to Texas Rule of Civil Procedure 501.4 by: ☐ Personal delivery Electronically Submitted 2/13/2024 12:00 PM Hidalgo County Clerk Accepted by: Sarah Reyes ☐ Mail ☐ Fax ☒ Email : Ian@barnettgarcia.com ☒ Another method approved by the court: E-Service Attorney for Defendants’ Signature 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. Hooman Khoshnood on behalf of Hooman Khoshnood Bar No. 24122796 hooman@hklawpc.com Envelope ID: 84450909 Filing Code Description: Amended Filing Filing Description: Amended Motion for Continuance Status as of 2/13/2024 12:02 PM CST Associated Case Party: RED TARGET LLC DBA SCJ COMMERCIAL FINANCIAL SERVICES Name BarNumber Email TimestampSubmitted Status Ian McCarthy ian@barnettgarcia.com 2/13/2024 12:00:50 PM SENT Associated Case Party: LOBOS RM TRUCKING LLC Name BarNumber Email TimestampSubmitted Status Hooman Khoshnood 24122796 hooman@hklawpc.com 2/13/2024 12:00:50 PM SENT Associated Case Party: MANUEL RENDON Name BarNumber Email TimestampSubmitted Status Hooman Khoshnood hooman@hklawpc.com 2/13/2024 12:00:50 PM SENT Associated Case Party: ROCIO RENDON Name BarNumber Email TimestampSubmitted Status Hooman Khoshnood hooman@hklawpc.com 2/13/2024 12:00:50 PM SENT Associated Case Party: MARIA RENDON Name BarNumber Email TimestampSubmitted Status Hooman Khoshnood hooman@hklawpc.com 2/13/2024 12:00:50 PM SENT Case Contacts 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. Hooman Khoshnood on behalf of Hooman Khoshnood Bar No. 24122796 hooman@hklawpc.com Envelope ID: 84450909 Filing Code Description: Amended Filing Filing Description: Amended Motion for Continuance Status as of 2/13/2024 12:02 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status assuredcivilprocessagency @yahoo.com assuredcivilprocessagency@yahoo.com 2/13/2024 12:00:50 PM SENT