On November 12, 2015 a
Motion,Ex Parte
was filed
involving a dispute between
Attorney General Of Texas,
Smith, Carlos Allen,
Smith, Tamisika Kofi,
and
Fort Bend Independent School District,
Vingle, Lynae,
Smith, Carlos Allen,
Smith, Tamisika Kofi,
for Divorce - With Children
in the District Court of Fort Bend County.
Preview
Filed
6/28/2016 1:47:52 PM
Annie Rebecca Elliott
District Clerk
Fort Bend County, Texas
Brittany Lopez
NO. 15-DCV-227783
IN THE MAY R-OF THE IN THE DISTRICT COURT
MARR OF
TA} K. SMITH
RLOS ALLEN S} 328th JUDICIAL DISTRICT
AND INTHEAN] EREST OF
FORT BEND COUNTY, TEXAS
OTIO FOR ONTINUAN'
Cx
COMES NO’ PY de Mil KA K. SMITH, and files this First Motion for
Continuance and as grounds|therefore wold show this Court the following:
{TRO TION
TAMISIKA K, SMITH is 41 cespond -Petitioner.
CARLOS ALLEN SM. isthe? tidne) Cousiex Respondent.
Discovery in this suit is go pred by a @ discovery control plan.
Mediation was completed on Ji % 20;
This case is set for trial on July 19, 20
B. FACTS
6 Discovery has not yet been completed. On 2016 Sherry B.
Angelo, Attorney for Respondent/Counter-Petitioner TAM SMITH)contacted
counsel for Petitioner/Counter-Respondent CARLOS ALLKk ey ding
discovery documents that she was unable to view and requested tht Oppo Ingct
resend the documents or provide the necessary password to open the docu on the
CD. As of today’s, Sherry B. Angelo has not received the documents. Please see
»
attached
The parties are currently working out a settlement agreement to finalize
th orce.
Angelo will be out of town on July 19, 2016, the date of trial, and
has dw no hed Oppo; ‘ounsel
CLUSION
ause of egoing, TAMISIKA K. SMITH requests that this case be
continued for 60 da:
RAYER
10. Wherefore onside: Respondent/Counter-Petitioner
TAMISIKA K. SMITH prays thai us mM: fo, ing and that the Motion for
Continuance be granted.
u lly itted,
/s/
SiS
Sherry B.
State Bar
1106 Vista
lo
No, 125957;
ive
A ©
Sugar Land, ‘47:
YY
Telephone: 281/313-
Facsimile: 713/23:
Sherr yo 80@: aol.
CERTIFICATE OF CONFERENCE
Ih certify that on June 16, 2016 and June 21, 2016 I attempted to discuss
with Robert Franks, the attorney of record for Petitioner/Counter-Respondent
RILOS ALLEN S} Hand have not received a response.
/s/ Sherry B. Angelo
Sherry B. Angelo
VO CE OF ING
Please take notice Respond, it/Counter-Petitioner TAMISIKA K. SMITH’s
Motion for Continuance is ‘OT0 © chy esday, July 6, 2016 at 8:30
a.m. in the 328% Judicial District Court 9 ou , Texas,
/sf oN
rry B
CE TIF] ERVICE
I certify that on the 27st day of June, 20 a trueal coryzec’ py of the
foregoing document was forwarded in accordant vith, the T Rules of Civil
Procedure to:
Robert D. Franks
One Sugar Creek Center Blvd., Suite 880
Sugar Land, Texas 77478
Facsimile: 281-242-2958
Email: Robert@fortbendjustice.com
/s/ Sherry B. Angelo
Sherry B. Angelo
Sher Angelo
From: Sherry Angelo
Sent: Monday, June 06, 2016 4:04 PM
To: ‘robert@fortbendjustice.com'
Ce
Subject: Ou Ico yning Production Responses
Mr. Frank
We were abl ‘0 open e ything of CD you gave us except for the folder labeled “Insurance Policies”. It says the
folder is password protected. provide me with that password or email us the documents contained in that
folder?
Thank you,
Angel:
Legal Secretary
Sherry B. Angelo
Attorney at Law
Three Sugar Creek Center, Suite 100
Sugar Land, Texas 77478
Telephone: (281) 313-2767
Facsimile: (713) 234-7370
herry9280 @aol.com
***IMPORTANT***
Please take note of Sherry Angelo's new ca ct jp a Q
NEW OFFICE ADDRESS:
Three Sugar Creek Center, Suite 100
YY
Sugar Land, Texas 77478
NEW MAILING ADDRESS:
1106 Vista Creek Drive
Sugar Land, Texas 77478
NEW FACSIMILE:
(713) 234-7370
RESPONDENT'S
IBIT
y
ROBERT D. FRANKS
Attorney at Law
pai,
Telephone (281) 2 42-2940
Facsimile (281) 242,
One Sugar Creck Center Blvd.. Suite 880
Sugar Land, Texas 77478
Website: www. fortbendjustice.com
Email: robert@fortbendjustice.com
March 23, 2016
Via RRR Mail- 7013-2250 0001 3884 6396
Sh Angelo
10% Corporate DB te. 135
zi
Stat
Re Ca ‘V-227783; In the Matter of the Marriage of Tamisika Smith and
d, In the Interest
dren; In the 328" Judicial District Court, Fort Bend County,
Mrs. Angelo,
Please find enefosed allawing items that are provided in response to your
written discovery:
Responses to Rey oduct
Responses to Interrogato: ‘S$; and
CD-ROM containing electro: ed-documents and items responsive to
production and disclosure
Should you have any complications ace pg thefil Sndined on the enclosed CD-
ROM, please contact our office so that we m ‘ist you j r retrieving those documents.
Thank you in advance for your courtesies Sidera tie
ie
Regp ‘tfully subi ad
42
Sy
: fp
Robert D. Fra
Ly
Attorney for Carlo;
Document Filed Date
June 28, 2016
Case Filing Date
November 12, 2015
Category
Divorce - With Children
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filed 6/28/2016 1:47:52 PM Annie Rebecca Elliott District Clerk Fort Bend County, Texas Brittany Lopez NO. 15-DCV-227783 IN THE MAY R-OF THE IN THE DISTRICT COURT MARR OF TA} K. SMITH RLOS ALLEN S} 328th JUDICIAL DISTRICT AND INTHEAN] EREST OF FORT BEND COUNTY, TEXAS OTIO FOR ONTINUAN' Cx COMES NO’ PY de Mil KA K. SMITH, and files this First Motion for Continuance and as grounds|therefore wold show this Court the following: {TRO TION TAMISIKA K, SMITH is 41 cespond -Petitioner. CARLOS ALLEN SM. isthe? tidne) Cousiex Respondent. Discovery in this suit is go pred by a @ discovery control plan. Mediation was completed on Ji % 20; This case is set for trial on July 19, 20 B. FACTS 6 Discovery has not yet been completed. On 2016 Sherry B. Angelo, Attorney for Respondent/Counter-Petitioner TAM SMITH)contacted counsel for Petitioner/Counter-Respondent CARLOS ALLKk ey ding discovery documents that she was unable to view and requested tht Oppo Ingct resend the documents or provide the necessary password to open the docu on the CD. As of today’s, Sherry B. Angelo has not received the documents. Please see » attached The parties are currently working out a settlement agreement to finalize th orce. Angelo will be out of town on July 19, 2016, the date of trial, and has dw no hed Oppo; ‘ounsel CLUSION ause of egoing, TAMISIKA K. SMITH requests that this case be continued for 60 da: RAYER 10. Wherefore onside: Respondent/Counter-Petitioner TAMISIKA K. SMITH prays thai us mM: fo, ing and that the Motion for Continuance be granted. u lly itted, /s/ SiS Sherry B. State Bar 1106 Vista lo No, 125957; ive A © Sugar Land, ‘47: YY Telephone: 281/313- Facsimile: 713/23: Sherr yo 80@: aol. CERTIFICATE OF CONFERENCE Ih certify that on June 16, 2016 and June 21, 2016 I attempted to discuss with Robert Franks, the attorney of record for Petitioner/Counter-Respondent RILOS ALLEN S} Hand have not received a response. /s/ Sherry B. Angelo Sherry B. Angelo VO CE OF ING Please take notice Respond, it/Counter-Petitioner TAMISIKA K. SMITH’s Motion for Continuance is ‘OT0 © chy esday, July 6, 2016 at 8:30 a.m. in the 328% Judicial District Court 9 ou , Texas, /sf oN rry B CE TIF] ERVICE I certify that on the 27st day of June, 20 a trueal coryzec’ py of the foregoing document was forwarded in accordant vith, the T Rules of Civil Procedure to: Robert D. Franks One Sugar Creek Center Blvd., Suite 880 Sugar Land, Texas 77478 Facsimile: 281-242-2958 Email: Robert@fortbendjustice.com /s/ Sherry B. Angelo Sherry B. Angelo Sher Angelo From: Sherry Angelo Sent: Monday, June 06, 2016 4:04 PM To: ‘robert@fortbendjustice.com' Ce Subject: Ou Ico yning Production Responses Mr. Frank We were abl ‘0 open e ything of CD you gave us except for the folder labeled “Insurance Policies”. It says the folder is password protected. provide me with that password or email us the documents contained in that folder? Thank you, Angel: Legal Secretary Sherry B. Angelo Attorney at Law Three Sugar Creek Center, Suite 100 Sugar Land, Texas 77478 Telephone: (281) 313-2767 Facsimile: (713) 234-7370 herry9280 @aol.com ***IMPORTANT*** Please take note of Sherry Angelo's new ca ct jp a Q NEW OFFICE ADDRESS: Three Sugar Creek Center, Suite 100 YY Sugar Land, Texas 77478 NEW MAILING ADDRESS: 1106 Vista Creek Drive Sugar Land, Texas 77478 NEW FACSIMILE: (713) 234-7370 RESPONDENT'S IBIT y ROBERT D. FRANKS Attorney at Law pai, Telephone (281) 2 42-2940 Facsimile (281) 242, One Sugar Creck Center Blvd.. Suite 880 Sugar Land, Texas 77478 Website: www. fortbendjustice.com Email: robert@fortbendjustice.com March 23, 2016 Via RRR Mail- 7013-2250 0001 3884 6396 Sh Angelo 10% Corporate DB te. 135 zi Stat Re Ca ‘V-227783; In the Matter of the Marriage of Tamisika Smith and d, In the Interest dren; In the 328" Judicial District Court, Fort Bend County, Mrs. Angelo, Please find enefosed allawing items that are provided in response to your written discovery: Responses to Rey oduct Responses to Interrogato: ‘S$; and CD-ROM containing electro: ed-documents and items responsive to production and disclosure Should you have any complications ace pg thefil Sndined on the enclosed CD- ROM, please contact our office so that we m ‘ist you j r retrieving those documents. Thank you in advance for your courtesies Sidera tie ie Regp ‘tfully subi ad 42 Sy : fp Robert D. Fra Ly Attorney for Carlo;